Crowell & Moring LLP (LexBlog Russia)

On August 23rd, 2024, the U.S. Treasury’s Office of Foreign Assets Control (OFAC), the U.S. Department of State (State), and the Commerce Department’s Bureau of Industry and Security (BIS) acted against Russia’s international supply chains. OFAC and State collectively sanctioned nearly 400 individuals and entities. Of note, this included a substantial focus on targeting non-Russian...

An overview on new Russian sanctions and export controls issued by the European Union, focusing on anti-circumvention measures and the Russian financial, military, and LNG industries. Click here to continue reading the full version of this alert.

On Wednesday, May 1, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that it issued new sanctions on nearly 200 entities and individuals for supporting Russia’s invasion of Ukraine, intensifying U.S. efforts to thwart Russia’s attempts to circumvent Western sanctions. The list includes more than a dozen of companies...

On February 20, 2024, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) issued Russia-related General License (GL) 83A, “Authorizing Certain Transactions Related to Imports of Certain Categories of Fish, Seafood, and Preparations Thereof Prohibited by Executive Order 14068.” On March 11, 2022, President Biden issued EO 14068 to prohibit, among other transactions,...

Feb. 23, 2024–Today, following the death of opposition politician and anti-corruption activist Aleksey Navalny, and after two years of Russia’s unprovoked and unlawful full-scale invasion of Ukraine, the Commerce Department’s Bureau of Industry and Security (BIS) imposed additional export restrictions on 93 entities under 95 entries in Russia and seven other destinations. Sixty-three of the...

On September 28, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), alongside the UK, Australia, Canada, New Zealand (termed the “Export Enforcement Five” or “E5,”), as well as the EU, issued new guidance with recommended best practices to help prevent a list of “high-priority items” from being diverted to Russia.  These...

Russia is reportedly unlikely to extend the Black Sea Grain Initiative, following negotiations in May to extend the deal past July 18th, which is the current deadline for all parties to either extend or collapse the deal.  The Black Sea Grain Initiative was initially brokered by the United Nations and Turkey between Russia and Ukraine...

Customs and Border Protection (CBP) released new guidance following the announcement of new 200% tariffs on Russian aluminum.  CBP’s guidance outlines new reporting requirements for all imports of aluminum and aluminum derivative products, regardless of the country of origin. The new reporting requirements follow the issuance of Presidential Proclamation 10522.  Under Proclamation 10522, any...

Global Trade Talks is a podcast that shares brief perspectives on key global issues on international trade, current events, business, law, and public policy as they impact our lives. In this podcast, hosts Nicole Simonian and Ambassador Robert Holleyman talk to Jason Prince, a Crowell & Moring Partner and immediate-past Chief Counsel to OFAC ,...

On Friday, the U.S. Department of Commerce Bureau of Industry and Security (BIS) issued its latest set of export controls in response to Russia’s invasion of Ukraine. The broadest expansion of U.S. export controls on Russia since last fall, Friday’s actions are separate and distinct from the new sanctions regulations imposed by the U.S. Department...

Washington, D.C. – January 23, 2023: Jason Prince, former chief counsel to the U.S. Treasury Department’s Office of Foreign Assets Control, has joined Crowell & Moring and will advise financial institutions and other companies on the growing list of sanctions and export controls on Russia and other targeted nations and parties. Prince brings in-depth experience...

On November 10, 2022, the U.S. Department of Commerce (“Commerce”) announced that it has reclassified Russia as a nonmarket economy, meaning that it will no longer treat Russia as a market economy in antidumping (AD) proceedings. This is an unprecedented move because it is the first time that Commerce upgraded a country to market economy...

EU Updates FAQS to Address Energy Security: On October 7, 2022, the EU updated two FAQs clarifying the impact of Council Regulation 833/2014 on the import, purchase and transfer of listed goods.  The EU clarified that Council Regulation 833/2014 prohibits the transfer of any listed goods if they originate in Russia or are exported from...

Sanctions Designations: U.S. Designates Numerous Individuals and Entities: On September 15, 2022, the U.S. added a number of individuals and entities to the Specially Designated Nationals and Blocked Persons (“SDN”) List.  The sanctions target Russia’s financial system, including the heads of Russia’s state-run card payment system (NSPK), central securities depository, stock exchange’s clearing...

Russia Sanctions: This week the European Union designated three additional individuals.  Two of the individuals are members of the Duma who undermined the territorial integrity, sovereignty, and independence of Ukraine by voting in favor of a resolution regarding the need to recognize the so-called Donetsk People’s Republic and Luhansk People’s Republic.  The other sanctioned person...

Russia Sanctions: This week the United Kingdom updated the listings for several sanctioned persons by making 17 amendments to designated individuals and 10 amendments to designated entities.  The amendments included revisions to dates of birth, addresses, and descriptions. General Licenses: On August 5, 2022, the United Kingdom issued general license (“GL”) INT/2022/2055384.  The GL allows...

EU Extends Sanctions Six Months: On July 26, 2022, the EU renewed restrictions on specific sectors of Russia’s economy until January 31, 2023.  This includes restrictions on finance, energy, technology and dual-use goods, industry, transport and luxury goods. UK Designates 41 More Individuals and One Additional Entity: On July 26, 2022, the UK designated a...

EU Extends Sanctions Six Months: On July 26, 2022, the EU renewed restrictions on specific sectors of Russia’s economy until January 31, 2023.  This includes restrictions on finance, energy, technology and dual-use goods, industry, transport and luxury goods. UK Designates 41 More Individuals and One Additional Entity: On July 26, 2022, the UK designated a...

On June 28, 2022, the Financial Crimes Enforcement Network (“FinCEN”) and the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a joint alert (the “Alert”), urging financial institutions regulated under the Bank Secrecy Act (“BSA”) to remain vigilant of efforts by third parties to evade the extensive U.S. export controls imposed on...

Russia Sanctions: This week the United Kingdom designated several additional individuals, primarily for contributing to the spread of disinformation about Ukraine and promoting Russian actions in Ukraine, or for their affiliation with organizations that have spread disinformation relating to Ukraine, such as SouthFront and NewsFront.  The United Kingdom also designated United World International,

Russia Sanctions: This week the United States designated dozens of additional entities and individuals as Specially Designated Nationals (“SDNs”).  Notable designations included State Corporation Rostec (“Rostec”), a large Russian state-owned company that operates in the automotive, defense, aviation, and metal industries; individuals who were part of a covert procurement network linked to Russia’

Russia Sanctions: The U.S. today designated two key supporters of an extremist group called the Russian Imperial Movement (“RIM”) under the Specially Designated Global Terrorist program.  OFAC explained that “RIM and its supporters continue to exacerbate Russia’s war of aggression in Ukraine through their fundraising efforts.”   The UK designated 12 individuals and entities under...

Russia Sanctions:  The EU and UK each made several amendments regarding previously-designated individuals and entities.  The amendments included corrections to names and dates of birth. General Licenses:  The U.S. made two announcements related to general licenses (“GLs”).  The U.S. announced that it will not renew GL 9C.  The specific provisions that expired are: (a)(1) –...

Russia Sanctions:  This week the UK designated 12 individuals and three Russian airlines, JSC Rossiya Airlines, JSC Ural Airlines, and PJSC Aeroflot.  The individuals include: (i) the chair of the board of directors of Russia’s National Media Group; (ii) a member of the board of directors of JSC SOGAZ (an EU- and UK-designated entity); (iii)...

Russia Sanctions:  The UK designated 63 individuals this week, including several war correspondents embedded with Russian forces in Ukraine that work at Channel One, a major state-owned media outlet in Russia.  The UK also designated one entity, Evraz PLC, a UK-incorporated holding company of a multinational steel manufacturing and mining company group.  Additionally, the UK...

Russia Sanctions:  The UK designated 63 individuals this week, including several war correspondents embedded with Russian forces in Ukraine that work at Channel One, a major state-owned media outlet in Russia.  The UK also designated one entity, Evraz PLC, a UK-incorporated holding company of a multinational steel manufacturing and mining company group.  Additionally, the UK...

Russia Sanctions:  There were limited developments this week.  There has been speculation that the EU would release its sixth round of sanctions against Russia, but no updates have been reported thus far.  The new package of sanctions is still expected soon.  The U.S. and UK also did not expand their list of designations this week. ...

Russia Sanctions:  The U.S., UK, and EU continue to apply pressure on Russia through the implementation of additional sanctions.  The U.S. designated dozens of additional individuals and entities under E.O. 14024, including Russian oligarch Konstantin Malofeyev – who had been previously designated by OFAC in 2014 under E.O. 13660 – and more than 40 individuals...

Russia Sanctions:  The UK and EU each made over 200 additional designations.  The EU designated several banks that the US previously had sanctioned, including Bank Otkritie, Novicombank, Sovcombank, and VTB Bank.  Both the EU and the UK designated several oligarchs including Alexander Petaykin (associated with Trans Stroy), Evgeny Zubitskiy (Industrial Metallurgical Holding), Grigory Berezkin (ESN

Global Trade Talks is a podcast that shares brief perspectives on key global issues on international trade, current events, business, law and public policy as they impact our lives. In this podcast, hosts Nicole Simonian and Ambassador Robert Holleyman talk to Crowell & Moring Partners’ Dj Wolff and Carlton Greene, who both specialize in economic...