Husch Blackwell LLP (LexBlog Russia)

Recently, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued new guidance to exporters intended to further assist BIS in its efforts to crack down on third-party diversion to Russia. Specifically, BIS’s recent guidance outlines the various mechanisms it has employed—outside of its usual public screening lists (i.e., the Unverified List, Entity...

Executive Order Imposes New Russia Sanctions for Foreign Financial Institutions and Prohibits Additional Russian Imports On December 22, 2023, President Biden issued Executive Order 14114, which amended previous Executive Orders in order to authorize the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) to impose additional Russia-related sanctions on foreign financial...

Check out the latest episode of The Justice Insiders—a podcast hosted by Husch Blackwell partner Gregg Sofer—where we explore the intersection of international trade law and government investigations and enforcement, particularly in connection with Russia. I previously appeared on Gregg’s podcast during the first quarter of 2022, and we pick up that conversation in order...

On May 19, 2023, the Department of Commerce’s Bureau of Industry and Security (“BIS”) announced new export controls and Entity List additions during President Biden’s G7 visit in Japan.  In conjunction with the G7 meetings, BIS stated these new restrictions are designed to better align U.S. controls with those of its partner and ally countries,...

On Friday, May 19, 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) announced the addition of more than 300 Russian Federation individuals and companies as well as other individuals and companies alleged to be aiding Russia’s war efforts to the Specially Designated Nationals and Blocked Persons (“SDN”) List. Simultaneously, the U.S....

On Friday, February 24, 2023, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued new sanctions against individuals and entities operating in Russia and against those assisting with Russia’s war efforts in Ukraine. In combination with OFAC’s additional sanctions, BIS also implemented additional export control measures and added 86 identified supporters of the...

On February 24, 2023, the Biden Administration announced the imposition of additional tariffs on Russian imports of aluminum and approximately 100 other individual products.  The imposition of these additional tariffs was announced on the one-year anniversary of Russia’s invasion of Ukraine. The White House announced its continued support of Ukraine in a series of actions...

The Department of Commerce’s Bureau of Industry and Security (“BIS”) announced today new export controls and Entity List additions designed to further restrict Russia’s ability to maintain its continued war against Ukraine. The Biden Administration’s measures come on the one-year anniversary of Russia’s invasion of Ukraine and the first announcement by several Western countries, including...

On December 15, 2022, the Office of Foreign Assets Control (“OFAC”) added 18 entities in Russia’s financial services sector to the Specially Designated Nationals and Blocked Persons List (“SDN List”). The US State Department concurrently designated Vladimir Potanin, one of the richest men in Russia. OFAC designated Public Joint Stock Company Rosbank (“Rosbank”), a bank...

On June 28, 2022, the Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) and the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a Joint Alert urging financial institutions to be vigilant against efforts by individuals or entities to evade BIS export controls implemented in connection with the Russian Federation’s further invasion...

On June 28, 2022, the Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) and the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a Joint Alert urging financial institutions to be vigilant against efforts by individuals or entities to evade BIS export controls implemented in connection with the Russian Federation’s further invasion...

On June 2, 2022, the Office of Foreign Assets Control (OFAC) added new Russian vessels and aircraft used by Russian elites, new top Russian government officials, and their companies and operations to the Specially Designated Nationals (SDN) List for aiding in the continued war effort by Russia against Ukraine.  Notably, these designations include more Russian...

On June 2, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) updated the Export Administration Regulations (“EAR”) to: (i) add 71 entities to the Entity List “for acquiring or attempting to acquire U.S.-origin items in support of Russia’s military”; (ii) issue minor revisions, corrections, and clarifications to its Russia and Belarus...

On May 8, 2022 the U.S. Department of the Treasury’s (“Treasury”) Office of Foreign Assets Control (“OFAC”) further escalated U.S. sanctions against the Russian Federation (“Russia”) by issuing two Determinations, adding new individuals and entities to the Specially Designated Nationals and Blocked Persons list (“SDN List”), and issuing three new general licenses in connection with...

On May 9, 2022, the Bureau of Industry and Security (“BIS”) released for public inspection a Final Rule adding hundreds of new items to a list of restricted items in Supplement No. 4 to Part 746 of the U.S. Export Administration Regulations (“EAR”).  BIS created the Supplement No. 4 list two months ago in March...

This blog post covers several new sanctions and export controls that the U.S. government imposed on Russia and Belarus in the time period occurring between March 31, 2022 and April 21, 2022.  As regular readers are aware, these restrictions are subject to frequent and sudden change.  For summaries of previously imposed sanctions and coverage on...

On March 30, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) modified and expanded a list of aircraft that have flown into Russia in apparent violation of the Export Administration Regulations (“EAR”).  We more thoroughly discussed the implications of this list – which was first published on March 18, 2022 –...

On March 24, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) updated the Specially Designated Nationals and Blocked Persons List (“SDN List”) with hundreds of new designations pursuant to Executive Order 14024.  The new SDNs include: The Russian Federation (“Russia”) State Duma (lower house of the Russian legislature) as an...

On March 24, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) updated the Specially Designated Nationals and Blocked Persons List (“SDN List”) with hundreds of new designations pursuant to Executive Order 14024.  The new SDNs include: The Russian Federation (“Russia”) State Duma (lower house of the Russian legislature) as an...

On March 18, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) publicly identified certain commercial and private aircraft that have entered Russia in likely violation of the Export Administration Regulations (“EAR”).  BIS provided an initial listing of nearly 100 Boeing aircraft owned and/or operated by Aeroflot, AirBridgeCargo, Aviastar-TU, Azur Air, Nordwind,...

On Friday, March 11, 2022, the White House issued Executive Order (“EO”) 14068 announcing more sanctions and export controls against the Russian Federation (“Russia”).  Concurrent with that announcement, the U.S. Commerce Department’s Bureau of Industry and Security (“BIS”) released new export controls restricting the flow of “luxury goods” to Russia, Belarus, and Russian/Belarusian “oligarchs...

Husch Blackwell’s latest podcast, The Justice Insiders, provides a unique perspective on some of the country’s most interesting criminal cases and issues related to compliance, internal investigations and regulatory enforcement. In episode 2, Husch Blackwell’s Gregg Sofer and Scott Glabe discuss implications of the United States’ broad and hastily enforced sanctions on Russia with Cortney Morgan,.

Husch Blackwell’s latest podcast, The Justice Insiders, provides a unique perspective on some of the country’s most interesting criminal cases and issues related to compliance, internal investigations and regulatory enforcement. In episode 2, Husch Blackwell’s Gregg Sofer and Scott Glabe discuss implications of the United States’ broad and hastily enforced sanctions on Russia with Cortney Morgan,.

On March 11, 2022, President Biden issued an Executive Order (“EO”) that prohibited the importation into the United States of 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...

On February 24, 2022, the U.S. imposed sweeping sanctions and export controls actions in response to the Russian Federation’s (“Russia”) “war of choice” against Ukraine.  (Husch Blackwell summarized the February 24, 2022 actions in a Client Alert published here, as well as more limited actions on February 21-22 here and here.)  The past ten (10)...

On February 22, 2022, one day after the Russian Federation formally recognized the Donetsk People’s Republic (“DNR”) and Luhansk People’s Republic (“LNR”) of Ukraine as “independent states” and the Biden Administration responded by imposing a sanctions embargo against the DNR and LNR regions, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) took further...

On February 22, 2022, one day after the Russian Federation formally recognized the Donetsk People’s Republic (“DNR”) and Luhansk People’s Republic (“LNR”) of Ukraine as “independent states” and the Biden Administration responded by imposing a sanctions embargo against the DNR and LNR regions, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) took further...

Russia has amassed more than 100,000 troops at the Ukrainian border, leading the White House to issue a warning on January 25 that the U.S. is “prepared to implement sanctions with massive consequences that were not considered in 2014 [when Russia invaded and annexed the Crimea region of Ukraine]” if Russia “further invades Ukraine”.  President...

As tensions run high between Washington and Moscow over a possibly imminent Russian invasion of Ukraine, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated today four (4) current and former Ukrainian officials under Executive Order (“EO”) 14024 dated April 15, 2021.  In a press release issued earlier today, OFAC asserted...

On June 30, 2021, CF Industries Nitrogen, LLC and its subsidiaries, Terra Nitrogen, Limited Partnership and Terra International (Oklahoma) LLC (“Petitioners”), filed a petition for the imposition of antidumping and countervailing duties on imports of certain urea ammonium nitrate solutions from Russia and the Republic of Trinidad and Tobago. SCOPE OF THE INVESTIGATION The merchandise...