Friday, Jun. 3, 2022
The EU Council adopted the sixth package of sanctions against Russia and Belarus. The new package, among other things, added several individuals and entities to the list of asset-freezing sanction targets of the EU, imposed sanctions on accounting, public relations and consultancy services to be provide to Russia, introduced a ban that will take place in few months against the importation of certain Russian crude oil and some refined products, de-SWIFTed additional Russian and Belarusian banks. Below there is a list of decisions published today as part of the sixth package:
COUNCIL IMPLEMENTING DECISION (CFSP) 2022/881 adding 12 individuals and eight entities to the list of EU asset-freezing sanctions targets;
COUNCIL DECISION (CFSP) 2022/882 de-SWIFTing Belinvestbank and expanding the export controls against Belarus;
COUNCIL DECISION (CFSP) 2022/883 adding 65 individuals and 18 entities to the list of EU asset-freezing sanctions targets; (press release)
COUNCIL DECISION (CFSP) 2022/884 expanding the scope of sanctions against Russia by introducing a ban on importation of certain crude oil and some refined produces, imposing restrictions on the activity of some Russian state-run media outlets, prohibiting the provision of accounting, auditing, and consulting services to Russia, and de-SWIFTing Sberbank, Credit Bank of Moscow, and Russian Agricultural Bank; (press release)
COUNCIL DECISION (CFSP) 2022/885 which is not part of the new package but rather an authorization for certain activities related to telecommunication operators.
Wednesday, May 25, 2022
On Feb. 28, 2022, OFAC issued Directive 4 under Executive Order 14024 prohibiting transactions involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation. To mitigate the negative impact of that prohibition on the U.S. person, OFAC issued General License 13A and authorized payments of taxes, fees, or import duties, and purchase or receive permits, licenses, registrations, or certifications to those entities through September 30, 2022. (Here)
Tuesday, May 24, 2022
In a new type of announcement, OFAC announced that it will not renew General License 9C under the Russian Harmful Foreign Activities Sanctions regulations. (Here)
Monday, May 23, 2022
OFSI issued a General License allowing transactions related to purchase of tickets from e PJSC Aeroflot, JSC Rossiya Airlines, JSC Ural Airlines, Russian Railways or their subsidiaries. (Here)
Friday, May 20, 2022
BIS issued an order denying the export privileges of a fifth Russian airline – Rossiya Airlines – due to ongoing export violations related to comprehensive export controls on Russia imposed by the Commerce Department. (Here)
Thursday, May 19, 2022
OFSI added three Russian airlines to its list of sanctions targets. (Here)
Friday, May 13, 2022
OFSI issued a General License allowing payments and other permitted activities to take place in relation to winding down activities, basic needs and insolvency proceedings associated with the Amsterdam Trade Bank N.V or a subsidiary of the same. (Here)
OFSI designated 12 individuals in the inner circle of Vladimir Putin (including his ex-wife). (Here, press release)
Wednesday, May 11, 2022
OFAC issued three FAQs defining some terms used in its recent determination and a newly issued General license. (Here)
Monday May 9, 2022
BIS released a rule (link here) building on its March 3, 2022, Russian Industry Sector Sanctions rule by expanding the scope of items subject to stringent license requirements. The new rule imposed a license requirement for exports, reexports, or transfers (in- country) to and within Russia for additional items subject to the Export Administration Regulations identified under specific Schedule B numbers or Harmonized Tariff Schedule codes. (Here)
Sunday, May 8, 2022
I cannot remember OFAC taking any actions over the weekend! This week that changed! OFAC surprised everyone by announcing a considerable expansion of sanctions against Russia. (Here, Treasury's press release) The new sanctions are:
Blocking sanctions against 33 individuals (including board members of some Russian banks), 22 entities (including a bank, a weapons manufacturer, and tv stations), and several vessels;
A determination was made pursuant to Section 1(a)(i) of Executive Order 14024. (Here) This determination allows for sanctions to be imposed on any individual or entity determined to operate or have operated in the accounting, trust and corporate formation services, and management consulting sectors of the Russian Federation economy and expands the United States’ ability to swiftly impose additional economic costs on Russia for its war of choice in Ukraine. Please note that a designation of a person is still needed;
A determination was made pursuant to section 1(a)(ii) of executive order 14071. (Here) By doing so OFAC prohibited the export, reexport, sale, or supply, directly or indirectly, from the United States, or by a U.S. person, wherever located, to any person located in the Russian Federation in the following sectors:
Accounting,
Trust and corporate formation; and
Management consulting
To mitigate the unintended impacts of the new sanctions OFAC issued Russia-related General License 25A, General License 33, General License 34, and General License 35 and published several new Frequently Asked Questions.
Thursday, May 5, 2022
DOJ announced the execution of a seizure warrant for freezing a yacht owned by sanctioned Russian oligarch Suleiman Kerimov in Fiji. The seizure warrant found that the yacht in question was subject to forfeiture based on probable cause of violations of U.S. law, including the International Emergency Economic Powers Act (IEEPA), money laundering and conspiracy. (Here)
OFAC issued Russia-related General License 7A (authorizing overflight payments, emergency landings, and air ambulance services), General License 26A, (replacing General License No. 26), General License 31(authorizing certain transactions related to patents, trademarks, and copyrights ), and General License 32 (authorizing the wind down of transactions involving Amsterdam Trade Bank NV). It also amended several FAQs and published FAQ 1032 which is about Afghanistan-related transactions with TKB.
UK designated Evraz PLC, major manufacturer of Russian steel. (Here, press release) Concurrently, OFSI issued General License - INT/2022/1710676 which allows for the continuation of business operations of three of the North American Subsidiaries of Evraz OLC: Evraz North America plc, Evraz Inc. NA, and Evraz Inc. NA – Canada.
Wednesday, May 4, 2022
OFSI added 63 entries to the list of financial sanctions targets under its Russia sanctions regime. (Here)
UK announced a ban on services exports, including management consulting, accounting and public relations, to Russia. (Here)
EU announced its sixth sanctions package (not officially yet). (Here) The new package as announced in a press release includes:
designation of high-ranking military officers and other individuals who committed war crimes in Bucha and who are responsible for the inhuman siege of the city of Mariupol;
"de-SWIFTing" Sberbank and two other major banks;
banning three big Russian state-owned broadcasters from EU's airwaves; and
Banning accountants, consultants and spin doctors from providing their services to Russian companies.
Tuesday, May 3, 2022
Australia issued Autonomous Sanctions (Designated Persons and Entities and Declared Persons—Russia and Ukraine) Amendment (No. 14) Instrument 2022, and Autonomous Sanctions (Designated Persons and Entities and Declared Persons—Russia and Ukraine) Amendment (No. 15) Instrument 2022 adding and amending several entries on its sanctions list.
The EU Council removed Russia from the scope of three of the Union general export authorizations (General Authorizations for EXPORT AFTER REPAIR/REPLACEMENT, TEMPORARY EXPORT FOR EXHIBITION OR FAIR, and TELECOMMUNICATIONS). (Here)
Monday, May 2, 2022
OFAC issued Russia-related General License 30, authorizing transactions involving Gazprom Germania GmbH prohibited by Directive 3 under Executive Order 14024.
Friday, April 29, 2022
The UK Parliament passed Russia (Sanctions) (EU Exit) (Amendment) (No. 9) Regulations 2022. (Here) The Amending Regulations introduced new restrictions on the provision of certain internet services to or for the benefit of designated persons In particular:
A person who provides a social media service must take reasonable steps to prevent content that is generated directly on the service, or uploaded or shared on the service, being encountered by a user of the service in the UK.
A person who provides an internet access service must take reasonable steps to prevent a user of the service in the UK from accessing an internet service provided by a designated person.
A person who provides an app store must take reasonable steps to prevent a user of that store from downloading or otherwise accessing an internet service provided by a designated person.
Wednesday, April 27, 2022
OFSI issued General License - INT/2022/1679676. The GL carved out activities of Crown Relevant Organisations from the scope of prohibitions provided certain conditions are met. It also permitted certain activities related ti asset recovery. (Here)
Monday, April 25, 2022
OFAC issued Ukraine-/Russia-related General License 13R (authorizing the wind Down of certain transactions necessary to divest or transfer debt, equity, or other holdings in GAZ Group) and General License 15L (authorizing the wind down of transactions involving GAZ Group). OFAC also published FAQ 592 to further explain the scope of GL 15L.
Friday, April 22, 2022
Australia added dozens of individuals to its list of sanctions under its Russia sanctions program. (Here, press release)
Thursday, April 21, 2022
OFSI added 26 entries to its list of asset-freezing sanctions targets. (Here, press release) As stated by the UK government these sanctions targeted individuals outside of Putin’s military who are actively supporting his illegal invasion of Ukraine.
The EU Council added two individuals to the list of asset-freezing sanctions targets under its Russia sanctions regime. (Here)
OFSI issued General License - INT/2022/1630477 to allow payments to Gazprombank or a Subsidiary for the purpose of making Gas available in the European Union. (Here) Reminder: Gazprombank was added to the list of asset-freezing sanctions on March 23, 2022.
BIS issued an order temporarily denying all export privileges for the Russian cargo aircraft carrier Aviastar due to ongoing violations of the comprehensive export controls imposed on Russia by the Commerce Department. Headquartered in Moscow, Aviastar provides a variety of cargo services to Russia. (Here)
The government of Japan put together a document outlining all the actions in has taken in response to the Russia's invasion. (Here)
The UK announced import bans on silver, wood products and high-end products from Russia including caviar and increased tariffs by 35 percentage points on around £130m worth of products from Russia and Belarus, including diamonds and rubber. (Here)
Wednesday, April 20, 2022
OFAC designated Transkapitalbank in Russia and several entities and individuals as part of a "sanctions evasion network." (Here, Treasury's press release) Concurrently, OFAC issued two general licenses:
General License 28 which allows transactions involving Transkapitalbank that are ultimately destined for or originating from Afghanistan; and
General License 29 which allows wind down activities involving Transkapitalbank through May 20, 2022.
The Department of State imposed several visa restrictions on individuals in Russia and Belarus. (Here)
OFAC published a new FAQ about credit cards payments related to cards issued by Russian Financial Institutions. (Here)
Tuesday, April 19, 2022
OFAC issued General License 27 allowing a broad range of transactions in support of NGOs activities that would have been otherwise prohibited by the Russian Harmful Foreign Activities Sanctions Regulations. OFAC also published a Fact Sheet on licenses in place under its Russia sanctions program. (Here, press release)
Wednesday, April 18, 2022
Spain also published some guidance to, among other things, remind financial obligations applicable to the private sector. (Here)
Thursday, April 14, 2022
OFSI designated two wealthy Russian citizens under its Russia sanctions regime. (Here)
The UK Parliament passed the Russia (Sanctions) (EU Exit) (Amendment) (No. 8) Regulations 2022 which introduces trade restrictions on:
oil refining goods, software and technology;
quantum computing and advanced materials goods, software and technology;
luxury goods; and
the import of iron and steel goods.
Following the passage of the new regulations, OFSI updated its Russia Guidance. (Here)
BIS identified 10 additional aircraft in likely violation of U.S. export controls, including the first seven Belarusian owned/operated commercial aircraft identified since restrictions on Belarus were tightened via regulation effective on April 8, 2022. The aircraft identified on the list have flown into Russia and/or Belarus in apparent violation of the Export Administration Regulations (EAR). (Press release, BIS list)
BIS issued a new rule to expands license requirements for Russia and Belarus under the Export Administration Regulations (EAR) to all items on the Commerce Control List (CCL). It also removed license exception eligibility for aircraft registered in, owned or controlled by, or under charter or lease by Belarus or a national of Belarus. Additionally, to recognize partner countries implementing substantially similar export controls on Russia and Belarus, the Department of Commerce published a list of countries excluded from certain U.S. export controls related to foreign-produced items. In this rule, the Department of Commerce adds Iceland, Liechtenstein, Norway, and Switzerland to the list of excluded countries. (Here)
Wednesday, April 13, 2022
The EU Council amended its decisions which imposed sanctions on Russia and Donetsk and Luhansk regions in order to carve out some humanitarian exceptions. In particular, organizations and agencies acting as humanitarian partners of the EU, such as the ICRC and the UN-specialized agencies, are exempted from the prohibition to make funds or economic resources available to persons and entities designated under the Ukraine territorial integrity regime when the funds or resources are necessary for exclusively humanitarian purposes in Ukraine. In addition, certain clearly defined categories of humanitarian organizations are exempted from the export restrictions and the related prohibition on the provision of services under the Donetsk and Luhansk regime when this is necessary for exclusively humanitarian purposes in the non-government controlled areas of the Donetsk and Luhansk oblasts of Ukraine. Furthermore, under both regimes, organizations not covered by the above exemptions can request Member States to grant a derogation from the same prohibitions when that is necessary for humanitarian activities in Ukraine. (Decisions, press release)
Australia designated 13 entities including Gazprom Neft, Russian Railways, Alrosa, and United Shipbuilding Corporation. (Here)
Malta published an updated guidance about the Russia sanctions. (Here)
The EU Parliament issued an in-depth analysis titled "Sanctions in the context of Russia’s invasion of Ukraine." (Here)
Tuesday, April 12, 2022
OFAC issued General License 26 under Russian Harmful Foreign Activities Sanctions program to allow wind-down transactions related to Joint Stock Company SB Sberbank Kazakhstan or Sberbank Europe AG through July 12, 2022. (Here)
DNB (the Central Bank of the Netherlands) issued some guidance about the recent EU sanctions against Russia. (Here)
Saturday, April 9, 2022
BIS issued final rule that expands its highly restrictive controls on the export and reexport of U.S.-origin and certain foreign-produced commodities, software, and technologies to Russia and Belarus, further choking off access to inputs and products needed to sustain their military capabilities. The new rule expands the license requirements on Russia and Belarus to all items designated on the CCL. (Press release)
Friday, April 8, 2022
OFSI also imposed sanctions against Putin's daughters. (Here, press release)
The fifth round of EU sanctions against Russia was published. It consisted of two Decisions:
COUNCIL DECISION (CFSP) 2022/582 - Imposing asset freezing sanctions against additional 217 individuals and 18 entities. (Press release)
COUNCIL DECISION (CFSP) 2022/578 - Significantly expanding the scope of pervasively-existing sanctions and introducing new restrictive measures. (Press release)
The EU Council also imposed further sanctions on Belarus. The new sanctions included (i) prohibition on the sale of transferable securities denominated in any official currency of a Member State to Belarus, and prohibition on the sale, supply, transfer or export to Belarus of banknotes denominated in any official currency of a Member Stat, and (ii) prohibition on any road transport undertaking established in Belarus from transporting goods by road within the territory of the Union, including in transit. (COUNCIL DECISION (CFSP) 2022/579)
Thursday, April 7, 2022
Australia imposed sanctions on additional 67 individuals for their role in Russia’s invasion of Ukraine. (Here)
OFAC designated a world's largest diamond mining company as a Russian state-owned enterprise pursuant to E.O. 14024. OFAC also re-designated United Shipbuilding Corporation which used to be a designated entity under E.O.13661. Today's designation was pursuant to E.O. 14024. OFAC also designated several of the United Shipbuilding Corporation subsidiaries and individuals related to it. (Here, the Department of the Treasury's press release, the Department of State's press release) Concurrently, OFAC issued Russia-related General License 9C, General License 10C, General License 21A, General License 24, and General License 25.
The U.S. Department of Commerce issued orders denying the export privileges of three Russian Airlines – Aeroflot, Azur Air, and UTair – due to ongoing export violations related to comprehensive export controls on Russia imposed by the Commerce Department. (Aeroflot Temporary Denial Order, Azur Air Temporary Denial Order, UTair Temporary Denial Order, and press release)
Wednesday, April , 2022
OFAC took a major step in ramping up sanctions against Russia by designating several individuals and entities including Alfa-Bank and Sberbank as SDN. (Here, the Department of the Treasury's press release, the Department of State's press release) To mitigate the unintended impact of recent sanctions, OFAC issued Russia-related General License 8B, General License 9B, General License 10B, General License 21, General License 22, and General License 23.
OFAC designated Vladimir Putin's daughters. (Here)
Tuesday, April 5, 2022
OFAC designated a crypto exchange, called Grantex, pursuant to E.O. 14024 for operating or having operated in the financial services sector of the Russian Federation economy. (Here, the Department of the Treasury's press release, the Department of State's press release)
Monday, April 4, 2022
Australia prohibited the supply, sale or transfer of certain luxury goods directly or indirectly to, for use in, or for the benefit of Russia. (Here)
DoJ published the news of seizing a yacht in Spain which belongs to a Russian SDN. The seizure warrant was issued in the U.S. based on allegations that the Tango was obtained in violation of U.S. bank fraud, money laundering, and sanction statutes. (DoJ press release)
Friday, April 1, 2022
BIS added 120 entities in Russia and Belarus to the Entity list. (Here)
Thursday, March 31, 2022
The U.S. Secretary of the Treasury determined that aerospace, electronics, and marine sectors of the Russian Federation economy should be added to the scope industries under section 1 (a)(i) of EO 14024. Previously, the technology sector or the defense and related materiel sector of the Russian Federation economy were named under this section. (Note that this is only a designation authority!) OFAC at the same time designated several individuals and entities under EO 14024 and section 224 of CAATSA. (Here, Treasury's press release, State Department press release)
UK designated more individuals and entities under its Russia sanctions regime. (Here)
Wednesday, Mar. 30, 2022
BIS updated list of aircraft that have flown into Russia in apparent violation of the Export Administration Regulations. (Here)
The UK imposed restrictions on providing technical services to Russian Oligarchs' aircrafts and ships in the UK. Also it extended the jurisdictional sanctions against non-government controlled areas of Donetsk and Luhansk regions. (Here, press release)
Monday, Mar. 28, 2022
The UK Cabinet Office published " Procurement Policy Note – Contracts with suppliers from Russia and Belarus." It requires that certain public entities:
Review their contract portfolio and identify any contracts where the prime contractor is a Russian or Belarusian supplier.
Where a Russian or Belarusian prime contractor is identified, they should consider terminating that contract in accordance with the terms of the contract i.e. following a legally compliant process.
Only proceed to terminate a contract if an alternative supplier can be sourced in line with value for money, affordability and with minimal disruption to public services
The Australian government for the first time used the authority granted to it under the Magnitsky sanctions program. As part of this action, 39 individuals were added to the Australian sanctions list and are subject to asset freezing sanctions. (Here, press release)
Friday, Mar. 25, 2022
OFSI updated its Guidance on the Russia (Sanctions) (EU Exit) Regulations 2019 to clarify that the prohibition on providing financial services for the purposes of foreign exchange reserve and asset management also applies to transactions involving gold. (Here)
Thursday, Mar. 24, 2022
OFSI added six entities in Belarus to its list of sanctions targets. (Here)
OFAC added hundreds of Duma member to the SDN list following a similar move from other western countries. OFAC also added new entities and notably the CEO of Sberbank to the SDN list. Furthermore, OFAC published a new FAQ about the gold-related transactions. (Here, Treasury's press release, DoS press release, and a fact sheet)
In a busy day for OFAC, it issued Russia-related General License 6A, General License 17A, General License 20, and Ukraine-/Russia-related General License 25. In addition, OFAC has updated two Frequently Asked Questions.
In a busy day for OFSI too, it designated Central Scientific Research Institute of Chemistry and Mechanics (TsNIIKhM) in Russia under its cyber sanctions. (Here)
Tuesday, Mar. 22, 2022
OFSI published an updated version of its General guidance for financial sanctions. (Here) In §4.1.4 of the guidance OFSI stated that when making an assessment on ownership and control, OFSI would not simply aggregate different designated persons’ holdings in a company, unless, for example, the shares or rights are subject to a joint arrangement between the designated parties or one party controls the rights of another (a clear distinction with OFAC's approach to the aggregation).
Monday, Mar. 21, 2022
Luxembourg's government issued an initial assessment of the implementation of sanctions against Russia. (Here)
Sunday, Mar. 20, 2022
Australia prohibits the export of aluminum ores, alumina and related products to Russia. (Here, press release)
Friday, Mar. 18, 2022
New Zealand imposed its first trench of autonomous sanctions against Russia. (Here) It imposed asset freezing and travel bans against Vladimir Putin and 12 permanent members of the Security Council of the Russian Federation. It also imposed several travel bans against several other individuals.
OFAC issued General License 24 which allows the transactions related to the provision or receipt of civil maritime services performed by individuals who are ordinarily resident in the so-called DNR or LNR regions of Ukraine as long as those are working for entities that are organized outside of those regions and the services is provided outside of those regions.
OFAC amended FAQ 1020 which was about dealings in Kazakh-origin crude oil of the Caspian Pipeline Consortium. (Here)
BIS identified commercial and private aircraft that have flown into Russia in apparent violation of the Export Administration Regulations (EAR). In so doing, BIS notified the public that providing any form of service to these aircraft requires authorization. (Here)
The Financial Services and Markets Authority of Belgium issued an announcement about the recent sanctions against Russia. (Here)
The Norwegian government published an update about the new Russia sanctions in Norway. (Here)
The Spanish government published a communication about the recent sanctions. (Here)
The Korean Financial Services Commission published a press release about the measures the Korean government is going to take to address cross-boarder payment issues amid Russia sanctions. (Here)
Thursday, Mar. 17, 2022
An interesting piece of news was the payment made by the Russian government related to its debt in USD. (Here) The payment seemed permissible under GL 9A.
Australia passed two pieces of regulations (press release):
Autonomous Sanctions (Designated Persons and Entities and Declared Persons—Russia and Ukraine) Amendment (No. 7) Instrument 2022 - Imposing sanctions against Viktor VEKSELBERG and Oleg DERIPASKA
Autonomous Sanctions (Designated Persons and Entities and Declared Persons—Russia and Ukraine) Amendment (No. 8) Instrument 2022 - Imposing sanctions on 11 Russian banks
Luxembourg's financial regulator (CSSF) issued a series of FAQs about international financial sanctions. (Here)
Netherlands DNB provided an update to the public about the new Russian sanctions. (Here)
Wednesday, Mar. 16, 2022
Australia, Canada, the European Commission, Germany, Italy, France, Japan, the UK, and US, launched the Russian Elites, Proxies, and Oligarchs (REPO) multilateral task force. The task force will facilitate the work among these countries to collect and share information to take concrete actions, including sanctions, asset freezing, and civil and criminal asset seizure, and criminal prosecution.(Here, FinCEN support announcement, EU Commission's press release)
Tuesday, Mar. 15, 2022
EU Council imposed its fourth round of sanctions against Russia by adopting two decisions:
COUNCIL DECISION (CFSP) 2022/429 of 15 March 2022 which added 15 individuals and 9 entities to the list of sanctions targets in the EU (press release), and;
COUNCIL DECISION (CFSP) 2022/430 of 15 March 2022 which prohibited all transactions with certain state-owned enterprises, prohibited the provision of any credit rating services to any Russian person, prohibited new investments in the Russian energy sector, tightened the export controls rules, and imposed trade restrictions concerning iron and steel, as well as luxury goods. (Press release)
EU Commission published a number of Q&As in the context of the new sanctions against Russia. (Here)
OFAC adde 15 individuals and one entity to the SDN list under Magnitsky program and the recently issued E.O. 14024. (Here, Department of the Treasury's press release, Department of States' press release)
The Department of State also used a range of authorities to impose visa restrictions (a type of sanctions) on several individuals in Russia and Belarus. (Here)
The UK's parliament passed the Economic Crime (Transparency and Enforcement) Act 2022. (The Act, Press release)
In two trenches, OFSI added 14 and 350 new entries to the list of UK's sanctions. (Here and here, press release)
The UK government has announced it will no longer issue any new guarantees, loans and insurance for exports to Russia and Belarus. (Here)
Monday, Mar. 14, 2022
The Monetary Authority of Singapore ("MAS") published two notices related to sanctions against Russia:
Notice SNR-N01 Financial Measures in Relation to Russia which imposed (i) blocking sanctions against four Russian banks, (ii) jurisdictional sanctions against DNR and LNR, and; (iii) debt/equity restrictions against the Russian government
Notice SNR-N02 Financial Measures in Relation to Russia – Non-prohibited Payments and Transactions which provided some carve-outs for designated persons
Germany's BaFin issued a number of FAQs about the recent sanctions against Russia. (Here in german only)
Sunday, Mar. 13, 2022
Australia added more than 30 Russian oligarchs to the list of sanctions in Australia. (Here
Friday, Mar. 11, 2022
Australia announced that it will prohibit the import of oil, refined petroleum products, natural gas, coal and other energy products from Russia. (Here)
OFSI added more than 300 entries to the list of sanctions targets in the UK. All the entries added as part of this package were Duma members. (Here, press release)
G7 issued a statement expressing their commitment in enforcing the sanctions imposed against Russia and in closing the loop-holes for evasion. (Here)
OFSI and FCA issued a joint statement on Sanctions and Crypto-assets. (Here)
The President of the U.S. issued another executive order which expanded the sanctions against Russia. The new executive order prohibits:
the importation into the United States of the following products of Russian Federation origin: fish, seafood, and preparations thereof; alcoholic beverages; non-industrial diamonds; and any other products of Russian Federation origin as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State and the Secretary of Commerce;
the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of luxury goods, and any other items as may be determined by the Secretary of Commerce, in consultation with the Secretary of State and the Secretary of the Treasury, to any person located in the Russian Federation;
new investment in any sector of the Russian Federation economy as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State, by a United States person, wherever located;
the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of U.S. dollar-denominated banknotes to the Government of the Russian Federation or any person located in the Russian Federation; and
any approval, financing, facilitation, or guarantee by a United States person, wherever located, of a transaction by a foreign person where the transaction by that foreign person would be prohibited by this section if performed by a United States person or within the United States.
OFAC added several individuals, a vessel, and an airplane to the SDN list under its Russia sanctions program. (Here) OFAC also issued three general licenses in light of the executive order that was issued on this day (General License 17, General License 18, and General License 19) as well as one general license related to humanitarian organizations to LNR and DNR regions. OFAC also published and amended several FAQs to explain and reflect the new sanctions. (Here)
Thursday, Mar. 10, 2022
OFSI added seven Russian oligarchs to the list of financial sanctions targets in the UK. (Here, press release) One of the targeted individuals under this package was Roman Abramovich, the owner of Chelsea FC. Concurrently, OFSI issued a general license authorizing many types of transactions related to Chelsea FC. (Here)
Canada made two regulatory updates which added several individuals and entities to its list of sanctions targets. (Here) Most importantly, Canada made it prohibited for any person in Canada and any Canadian outside Canada to import, purchase or acquire Petroleum oils and oils obtained from bituminous minerals, crude as well as some other oil and gas-related products, wherever situated, from Russia or from any person in Russia. (Here)
Wednesday, Mar. 9, 2022
EU imposed further sanctions against Belarus and Russia. In particular:
Council Decision (CFSP) 2022/397 - Targeting 14 oligarchs and prominent businesspeople along with 146 members of the Russian Federation Council; (press release)
Council Decision (CFSP) 2022/395 - Introducing new export control restrictions
Council Decision (CFSP) 2022/399 - Imposing sanctions on Belarus Central Bank, prohibiting provision of financial messaging services to three Belarusian banks, prohibition of certain deposits in the excess of EUR 100,000, and other measures. (Press release)
OFSI issued a general license authorizing certain transactions related to Provision of navigational data to civilian aircrafts for flight safety under its Belarus sanctions regime. (Here)
Tuesday, Mar. 8, 2022
The UK's Parliament passed the Russia (Sanctions) (EU Exit) (Amendment) (No. 6) Regulations 2022. (Press release) The new sanctions imposed as part of this amendment included:
new powers to detain Russian aircraft and remove aircraft belonging to designated individuals and entities from the UK register
ban on the export of aviation and space-related goods and technology, including technical assistance
further ban on UK companies providing insurance and re-insurance services in relation to these goods and technology
Following the passage of the new regulations, OFSI updated its Russia guidance. (Here)
The President of the U.S. issued an executive order which prohibited the following:
the importation into the United States of the following products of
Russian Federation origin: crude oil; petroleum; petroleum fuels, oils, and products of their distillation; liquefied natural gas; coal; and coal products;
new investment in the energy sector in the Russian Federation by a United States person, wherever located; and
any approval, financing, facilitation, or guarantee by a United States person, wherever located, of a transaction by a foreign person where the transaction by that foreign person would be prohibited by this section if performed by a United States person or within the United States.
OFAC issued a general license allowing certain transactions through April 22. (Here) OFAC also published and amended several FAQs. (Press release)
In a non-sanction yet Russia related development, DoJ published a press release about charges brought against a dual U.S.-Russian national which allegedly acted illegally as a Russian agent in U.S. (Here)
Monday, Mar. 7, 2022
FinCEN issued an alert highlighting some of the red flags for financial institutions in the context of the recent Russia sanctions. (Here)
Friday, Mar. 4, 2022
Thursday, Mar. 3, 2022
OFAC listed several individuals and entities under its Russia program. Concurrently OFAC issued General License 15 allowed transactions with the non-listed shadow SDNs that are related to an SDN which was sanctioned as part of this day's package. (Here, press release)
Wednesday, Mar. 2, 2022
The EU Councils announced a new round of sanctions against Russia by prohibiting provision of specialized financial messaging services to some Russian banks. This means SWIFT would need to stop working with those banks. Yet, this prohibition is not only for SWIFT and it is broader than it. (Press release, Council Decision 2022/346)
The EU Council imposed a new type of sanctions (it's not financial) against Russian media outlets in Europe. (Press release, Council Decision 2022/351) If you want to follow all the EU sanctions in response to the Ukraine crisis you can check this page.
OFAC issued four Russia-related general Licenses: General License 9A, General License 10A, General License 13, and General License 14 as well as some FAQs. (Here, press release) General License 14 is significant because it allows transactions in which the Russian Central Bank is involved just for the sake of clearing.
Tuesday, Mar. 1, 2022
Canada imposed blocking sanctions on additional 18 individuals (including Vladimir Putin) in Russia. (Here) You can check the Canada's government dedicated page for all the sanctions imposed so far.
Monday, Feb. 28, 2022
The EU Council added more sanctions against Russia. (Here) In particular:
Council Decision CFSP) 2022/337 of 28 February 2022 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine which imposed blocking sanctions on 26 individuals and one entity due to their ties with Vladimir Putin.
Council Decision 2022/335 of 28 February 2022 amending Decision 2014/512/CFSP concerning restrictive measures in view of Russia’s actions destabilizing the situation in Ukraine which imposed sanctions on the Russian Central Bank.
Singapore joined other western countries by adding new sanctions against Russia. (Here)
Australia added another step in sanctioning Russia by taking the following measure: (Here)
Removal of selected Russian banks from the SWIFT global payments messaging system
Restrictive measures to prevent the Russian Central Bank from using its international reserves in a way that undermines sanctions
Limiting so-called golden passports for wealthy Russians connected to the Russian government
A trans-Atlantic task force to identify and freeze the assets of sanctioned individuals and companies that exist within their jurisdictions.
South Korea also joined the other western countries by announcing its own sanctions against Russia. (Here)
OFAC imposed sanctions on the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation. Even though the sanctions imposed are not of an asset-freezing nature, they prohibit any transactions involving the three entities. (Here, press release) OFAC also added an individual and three entities to its SDN list.
OFSI listed three entities (banks). (Here)
Saturday, Feb. 26, 2022
The European Commission, France, Germany, Italy, the United Kingdom, Canada, and the United States issued a joint statement, announcing their intention to impose further sanctions against Russia. (Here)
Friday, Feb. 25, 2022
The EU Council adopted several decisions expanding the existing sanctions against Russia: (here)
Council Decision (CFSP) 2022/327of 25 February 2022 amending Decision 2014/512/CFSP concerning restrictive measures in view of Russia’s actions destabilizing the situation in Ukraine which expanded the scope of financial services and access to the European capital for Russia as well as limiting the amount that could be deposited from Russia. This decision also expanded the export controls restrictions against Russia and imposed some sanctions targeted at certain economy sectors of Russia (Technology, transport, and Energy).
Council Decision (CFSP) 2022/329 of 25 February 2022 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine which expanded the designation grounds in light of the situation in Ukraine.
Council Decision (CFSP) 2022/331 of 25 February 2022 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine Council Decision which added several entities and individuals to the EU sanctions list.
Japan also imposed further sanctions against Russia. In particular, Japan will: (here)
To suspend the issuance of entry visas to Japan for designated individuals related to Russia and freeze the assets held by designated individuals and entities related to Russia in Japan.
To freeze assets of three Russian banks (VEB.RF, Promsvyazbank, Bank Rossiya) in Japan.
To impose sanctions on exports to Russian military-related entities, on exports of controlled items listed on the internationally agreed list and of other dual-use goods such as semiconductors.
Thursday, Feb. 24, 2022
Japan also announced its sanctions against Russia. (Here) The U.S. Department of State gave kudos to Japan for doing this. (Here) The new sanctions are:
Japan will suspend the issuance of entry visas to Japan for individuals of the "Donetsk People's Republic" and the "Ruhansk People's Republic" and freeze the assets held by these individuals in Japan;
Japan will prohibit import from and export to the "Donetsk People's Republic" and the "Ruhansk People's Republic";
Japan will prohibit the issuances and transactions of new Russian sovereign debt in the primary and secondary market. Japan will also expand the coverage of maturity regarding existing prohibitions of bond issuances by designated Russian banks.
Russia attacks Ukraine.
OFAC imposed blocking sanctions against 24 Belarusian individuals and entities due to Belarus’s support for, and facilitation of, the invasion. Two major state-owned banks were among the designated persons in this designation package. (Here)
In additions to sanctioning Belarusian entities and individuals, OFAC unveiled a major sanctions package (the second one in a week) against Russia. The second wave of sanctions included the following measures:
Imposed Correspondent and Payable-Through Account Sanctions on Sberbank and 25 of its subsidiaries. OFAC issued Directive 2 under E.O. 14024 ("Russia-related CAPTA Directive"). The Directive prohibits: (i) the opening or maintaining of a correspondent account or payable-through account for or on behalf of any entity determined to be subject to the prohibitions of the Russia-related CAPTA Directive, or their property or interests in property; and (ii) the processing of transactions involving any such entities determined to be subject to the Russia-related CAPTA Directive, or their property or interests in property. (There's a grace period for these restrictions to kick in!)
Imposed blocking sanctions against VTB Bank, Otkritie, Sovocombank, and Novikombank.
Added additional debt and equity prohibitions by issuing Directive 3 under E.O. 14024 ("Russia-related Entities Directive"). The directive prohibits transactions and dealings by U.S. persons or within the United States in new debt of longer than 14 days maturity and new equity of those listed under this directive.
Imposed blocking sanctions against those who are close to Vladimir Putin.
OFAC issued several general licenses and FAQs. (Here, press release)
The UK's Prime Minister announced some new sanctions against Russia: (here)
Imposing blocking sanctions on VTB Bank
Imposing restrictions on the access of Russian financial institutions to Sterling and clearing payments through the UK
Restricting the access to financial and capital for certain Russian entities
Limiting the amount of money that Russian nationals can deposit in their UK bank accounts
Several new designations in Russia and Belarus
Banning Aeroflot from the UK
New export controls that would ban the export of all dual-use items to Russia
Canada imposes blocking sanctions against hundreds of entities and individuals in Ukraine. It also imposed a dealing bank on the non-government controlled areas of Donetsk and Luhansk. (Here)
Wednesday, Feb. 23, 2022
The EU Council published four new decisions and four new regulations implementing those decisions regarding the additional sanctions on Russia. (Here)
Council Decision (CFSP) 2022/264 introduced restrictions against Russia's access to EU financial and capital markets
Council Decision (CFSP) 2022/265 which amended Decision 2014/145/CFSP by adding new names as sanctions targets including the Russian defense minister, many other high-ranking Russian officials, Bank Rossiya, PROMSVYAZBANK, and VEB.RF.
Council Decision (CFSP) 2022/266 introduced jurisdictional sanctions against DNR and LNR.
Council Decision (CFSP) 2022/267 amending Decision 2014/145/CFSP by adding scores of Duma members who voted in favor of the recognition of DNR and LNR.
Australia announced its sanctions. (Here) The Australian sanctions so far are:
Travel bans and targeted financial sanctions on eight members of Russia’s Security Council
Blocking sanctions on Rossiya Bank, Promsvyazbank, IS Bank, Genbank and the Black Sea Bank for Development and Reconstruction
Restrictions on Australians investing in the state development bank VEB
Jurisdictional sanctions in the regions of Donetsk and Luhansk prohibiting trade in the transport, energy, telecommunications, and oil, gas and minerals sectors.
OFAC finally imposed sanctions on Nord Stream 2 AG and its Managing Director. (Here) Concurrently, OFAC issued a new wind down general license valid through March 2, 2022.
Tuesday, Feb. 22, 2022
The UK's OFSI added three individuals and five banks to its list of financial sanctions targets. Four of the designated banks were designated due to their role in Crimea. The other one, PJSC Promsvyazbank, was designated because of its support of Russia's military. (OFSI Notice, the UK Gov's press release)
The EU Commission issued a statement announcing that an informal meeting of EU Foreign Affairs Ministers chaired by the High Representative will take place at 4 pm CET to discuss and pass the first tranche of the EU sanctions in response to Russia's recognition of DNR and LNR. The EU sanctions package will likely include restrictive measures that:
Target those who were involved in the illegal decision;
Target banks that are financing Russian military and other operations in those territories;
Target the ability of the Russian state and government to access the EU's capital and financial markets and services, to limit the financing of escalatory and aggressive policies; and,
Target trade from the two breakaway regions to and from the EU, to ensure that those responsible clearly feel the economic consequences of their illegal and aggressive actions.
Germany decided to halt the Nord Stream 2 project by stopping the project's certification process. (Here)
Australia announced that it will impose sanctions on Russia. (Here)
Japan says it is ready to join the U.S.-led sanctions on Russia. (Here)
The EU announced its sanctions against Russia. (Watch the press conference here.)Those are:
Blocking sanctions against 351 members of the Russian State Duma who voted for the recognition of the so-called LPR and DPR;
Blocking sanctions against 27 individuals and entities who are undermining #Ukraine’s territorial integrity, sovereignty & independence. These include entities that are active in the defense sector of Russia and banks which support the military actions of Russia against Ukraine;
Crimea-style sanctions that limit the economic relations between the two breakaway regions and the European Union; and,
Financial sanctions that limits the ability of the Russian state to access the EU’s capital and financial markets.
OFAC announced some major sanctions against Russia. Interestingly, all of the sanctions were imposed pursuant to the authority granted in Executive Order 14024 and not the Executive Order that was issued yesterday. The new sanctions measures are:
Blocking sanctions against two major Russian banks, Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank (VEB) and Promsvyazbank Public Joint Stock Company (PSB), along with 42 of their subsidiaries as well as five vessels owned by PSB Lizing OOO, a designated subsidiary of PSB.
Blocking sanctions against three individuals close to the Russian President;
Restrictions on capital. OFAC amended Directive 1 under E.O. 14024 by issuing Directive 1a which extends existing sovereign debt prohibitions to cover participation in the secondary market for bonds issued after March 1, 2022 by the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation. (Certain types of participation in the primary market for bonds issued by these entities as well as certain lending activities were already subject to restrictions.)
Concurrent with the new sanctions, OFAC issued two general licenses, published two FAQs, and amended several FAQs. (General License 2, General License 3, New FAQs, and Updated FAQs.) (Press release)
Canada also announced its sanctions against Russia. (Here) These new measures will:
Impose restrictions on members of the Russian State Duma who voted for the decision to recognize the independence of the Donetsk and Luhansk;
Impose a dealings ban on the non-government controlled areas of Donetsk and Luhansk, which will effectively prohibit Canadians from engaging in specific transactions and activities in these regions;
Place new prohibitions on direct and indirect dealings in Russian sovereign debt; and
Impose sanctions on two significant Russian financial institutions in order to hinder Russia’s ability to further fund its aggressive actions.
Monday, Feb. 21, 2022
Following the Russia's recognition of two separatist regions in Ukraine as independent states earlier today, the U.S. President just issued an Executive Order (Executive Order on Blocking Property of Certain Persons and Prohibiting Certain Transactions With Respect to Continued Russian Efforts to Undermine the Sovereignty and Territorial Integrity of Ukraine) which expanded the scope of the national security declared in Executive Order 13660 of March 6, 2014 (Blocking Property of Certain Persons Contributing to the Situation in Ukraine), which itself had been expanded by Executive Order 13661 of March 16, 2014 (Blocking Property of Additional Persons Contributing to the Situation in Ukraine), Executive Order 13662 of March 20, 2014 (Blocking Property of Additional Persons Contributing to the Situation in Ukraine), and relied on Executive Order 13685 (Blocking Property of Certain Persons and Prohibiting Certain Transactions With Respect to the Crimea Region of Ukraine) of December 19, 2014, and Executive Order 13849 of September 20, 2018 (Authorizing the Implementation of Certain Sanctions Set Forth in the Countering America's Adversaries Through Sanctions Act).
Today's Executive Order prohibits the following:
New investment in the so-called Donetsk People’s Republic (DNR) or Luhansk People’s Republic (LNR) regions of Ukraine by a United States person, wherever located;
The importation into the United States, directly or indirectly, of any goods, services, or technology from the so-called DNR or LNR regions of Ukraine;
The exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of any goods, services, or technology to the so-called DNR or LNR regions of Ukraine;
And any approval, financing, facilitation, or guarantee by a United States person, wherever located, of a transaction by a foreign person where the transaction by that foreign person would be covered by these prohibitions if performed by a United States person or within the United States.
In addition to the above-mentioned prohibitions, today's Executive Ordered provided very broad grounds for designations, on the following persons:
To operate or have operated since the date of the order in the so-called DNR or LNR regions of Ukraine;
To be or have been since the date of the order a leader, official, senior executive officer, or member of the board of directors of an entity operating in the so-called DNR or LNR regions of Ukraine;
To be owned or controlled by, or to have acted or purported to act for or on behalf of, directly or indirectly, any person whose property and interests in property are blocked pursuant to this order;
Or to have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, any person whose property and interests in property are blocked pursuant to this order.
As of the time of this publication (Feb. 21, 2022, 7:07 pm EST), the Department of the Treasury is yet to designate any persons under these new grounds. The White House stated that the Department of the Treasury will issue six general licenses to minimize the unintended negative impact of the new sanctions against the Ukrainian government and the people living in the covered regions. The general licenses will allow the following activities that would have been otherwise prohibited by Today's Executive Order:
The licenses allow a short-term wind down of activities, as well as for the export to the regions of food, medicine and medical devices, and ensure personal remittances can continue to flow.
The licenses also allow telecommunications and internet services to remain operational, and mail services to continue.
The licenses allow international organizations to be able to provide aid to the people in these two regions.
Following the White House statement, OFAC issued six general licensed:
General License No. 17: Authorizing the Wind Down of Transactions Involving the So-called Donetsk People’s Republic or Luhansk People’s Republic Regions of Ukraine (here)
General License No. 18: Authorizing the Exportation or Reexportation of Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates to Certain Regions of Ukraine and Transactions Related to the Coronavirus Disease 2019 (COVID-19) Pandemic (here)
General License No. 19: Authorizing Transactions Related to Telecommunications and Mail (here)
General License No. 20: Official Business of Certain International Organizations and Entities (here)
General License No. 21: Authorizing Noncommercial, Personal Remittances and the Operation of Accounts (here)
General License No. 22: Authorizing the Exportation of Certain Services and Software Incident to Internet-Based Communications (here)
This post will be updated as the situation evolves.