LexBlog (LexBlog Russia)

The Russian financial services sector remains a key target of U.S., UK, and EU sanctions.  As discussed below, a number of recent such sanctions against Russia and countermeasures by the Russian government  have further complicated efforts for investors seeking to divest listed securities from Russia. As mentioned in our previous alert, on November 21, 2024,...

Boris Godunov is an opera based on the historical events surrounding the rise and fall of the Russian Tsar of the same name.  Written by Russian composer Modest Mussorgsky, the opera is set in the early 17th century, a time of great turmoil in Russia.  Exploring themes of legitimacy, power, and the burden of leadership,...

As anticipated by recent media coverage, the Governmental Commission for Control over Foreign Investments (the “Governmental Commission”) published its October 15, 2024 decision tightening conditions for exits by investors from “unfriendly” jurisdictions (i.e., those that have imposed sanctions against Russia) (the “Decision”).  Prior to the Decision, the Governmental Commission had already...

The primary objective of this guidance is to ensure industry compliance with export controls and help businesses identify risks associated with circumvention of export restrictions directed against the Russian military-industrial complex. The joint guidance identifies the following priority areas: (i)products posing an increased risk of reexport to Russia; (ii) red flag indicators of potential...

Forum 18 reports that Ukraine’s Law No. 3894-IX (full text in Ukrainian) signed into law on August 24 came into force on Monday. According to the report: The Law bans the Russian Orthodox Church – Moscow Patriarchate (ROC) for its justification and proactive support of Russia’s invasion of Ukraine. The Law identifies the ROC as a...

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...

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...

There are lots of strategies for winning a chess match. Most gambits are named for people, but some have funny names like the Alien Gambit, the Zilbermints Double Countergambit, and the Fried Liver Attack. At a chess tournament earlier this month in Makhachkala, Russia, one competitor tried a new strategy. She (allegedly) smeared mercury on...

It is heartwarming that 16 prisoners, including innocent ex-Marine Paul Whelan and Wall Street Journal reporter Evan Gershkovich, have been freed from their wrongful imprisonment in Russia in exchange for 24 convicted Russian prisoners. What is disturbing is that innocent individuals wrongfully convicted are being used to bargain for convicted individuals, including cybercriminals. Krebs on...

Anecdotally, we know that cybercriminals hailing from Russia are a significant risk to U.S.-based and world companies and governmental entities. With two convicted Russian cybercriminals being released this week in the prisoner swap I was curious just how significant Russian cybercriminals play in cybercrime chaos. According to Bleeping Computer, “Russian-speaking threat actors accounted for at...

Moscow Times and Vyorstka reported yesterday that a Russian District Court in Moscow has banned the offering on four websites in Russia of souvenir toilet paper imprinted with images of the 1997 version of Russia’s 1000-ruble bills. The court found that the toilet paper “offends the feelings of religious believers” in violation of Article 148 of...

On 24 June 2024, the Council of the European Union (the “Council”) adopted a new package of economic sanctions against Russia. This 14th package of sanctions introduces a broad range of new prohibitions, including new export and import sanctions, new services restrictions, new sanctions designations and further measures targeting the Russian financial and energy sectors....

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.

In the Biden Administration’s continuing effort to reduce the risk of cybersecurity spyware from foreign adversaries, including Russia, the United States Department of Commerce (Commerce) issued a final rule (Rule) on June 16, 2023, entitled “Protecting Americans’ Sensitive Data from Foreign Adversaries” and also amended a previously issued rule (“Securing the Information and Communications...

On June 12, 2024, the US Department of Commerce Bureau of Industry and Security (BIS) imposed additional export control measures against Russia and Belarus by expanding the scope of items subject to the Export Administration Regulations (EAR) sectoral sanctions. The amendments to the EAR were issued in conjunction with the issuance of sanctions against over...

Last year, we published an update on BIS’s foray into prohibiting EAR99 items for export to Russia and Belarus. We noted (somewhat in jest) that kitchen sinks may one day be added. Well, that day has come. Stainless steel kitchen sinks are officially prohibited for export to Russia and Belarus. In our recent blog article...

June 18, 2024, Covington Alert On June 12, 2024, the U.S. Department of the Treasury, Office of Foreign Assets Control (“OFAC”) and the U.S. Commerce Department, Bureau of Industry and Security (“BIS”) issued additional measures to counter Russia’s continued aggression in Ukraine. The measures, announced in advance of the G7 summit in Italy last week, are...

On June 12, 2024, the US government announced a broad package of measures aimed at increasing the extent of economic pressure on Russia and curtailing Russian circumvention of US sanctions and export controls. The measures are a joint effort by the US Department of the Treasury’s Office of Foreign Assets Control (OFAC), the US Department...

On June 12, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced new measures targeting Russia’s financial infrastructure, including: As we assess the new announcements we will publish additional analysis of the new restrictions as soon as possible.

On June 12, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced new measures targeting Russia’s financial infrastructure, including: As we assess the new announcements we will publish additional analysis of the new restrictions as soon as possible.

On May 23, 2024, Russian Presidential Decree No. 442 (the “Decree”), which establishes the framework that will allow the Russian government to seize any U.S. assets in Russia, was signed. This comes just weeks after the U.S. Rebuilding Economic Prosperity and Opportunity for Ukrainians (REPO) Act, which authorizes the President of the United States to...

In response to the growing threat by pro-Russia hacktivists, on May 1, 2023, CISA and other national agency partners issued an Alert to operators of industrial control systems and small-scale operational technology systems in North America and Europe on mitigation techniques for cyber operations to prevent a compromise of industrial control systems, including “Water and...

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...

In response to the growing threat by pro-Russia hacktivists, on May 1, 2023, CISA and other national agency partners issued an Alert to operators of industrial control systems and small-scale operational technology systems in North America and Europe on mitigation techniques for cyber operations to prevent a compromise of industrial control systems, including “Water and...

In response to the growing threat by pro-Russia hacktivists, on May 1, 2023, CISA and other national agency partners issued an Alert to operators of industrial control systems and small-scale operational technology systems in North America and Europe on mitigation techniques for cyber operations to prevent a compromise of industrial control systems, including “Water and...

The recent omnibus foreign relations package signed by President Biden on April 24, 2024, includes the Protecting Americans’ Data from Foreign Adversaries Act of 2024 (the Act), a set of sweeping privacy provisions prohibiting data brokers from sharing sensitive personal information with a broad range of entities that may have ties to Russia, China, Iran, and...

The EU is going extraterritorial, and it is doing so through private contract. It is a pretty neat trick. As a general rule, EU regulations do not apply extraterritorially. This policy is a bit pointed, intended to stand in sharp contradistinction to the U.S. sanctions regulations that are enforced around the world (and for which...

In early March, the EU released its first-ever European Defence Industrial Strategy (EDIS), accompanied by a proposed regulation establishing the European Defence Industry Programme (EDIP). The aim is to boost defence capabilities in Europe through greater and more efficient spending. In particular, the strategy seeks to reverse recent trends, whereby 78% of defence acquisitions by...

I recently shared insights on the landscape of U.S. sanctions on Russia for a story in The Washington Post entitled “Why the U.S. Put a $1 Million Bounty on a Russian Yacht’s Alleged Manager.” U.S. authorities offered a $1 million reward for information that would lead to the arrest or conviction of the man they...

On February 16, 2023, almost one year after the onset of Russia’s full-scale invasion of Ukraine and among increasing scrutiny of broader geopolitical threats to US supply chains, the US Department of Commerce’s Bureau of Industry and Security (BIS) and the Department of Justice’s National Security Division (NSD) announced the creation of the “Disruptive Technology...