Bart M. McMillan, Author at Global Sanctions and Export Controls Blog

US Government Designates Russian Proxy Wagner Group as a Significant Transnational Criminal Organization; Sanctions Wagner Group Affiliates, Oligarch Affiliates, and Military Industrial Complex Firms

January 31, 2023 By Bart M. McMillan, Alexandre (Alex) Lamy and Rob O'Brien 2 Mins Read

On January 26, 2023, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) redesignated PMC Wagner (“Wagner Group”) a Significant Transnational Criminal Organization (“STCO”) pursuant to Executive Order 13581 (“EO 13581”) as amended by Executive Order 13863 (“EO 13863”) for the Wagner Group’s activities in Ukraine, the Central African Republican (“CAR”), and Mali. Concurrently, OFAC has sanctioned the Wagner Group under Executive Order 13667 (“EO 13667”) for its activities in the CAR.…

OFAC and BIS Designate Additional Russian Parties, Signal Readiness to Act Against Third-Country Entities Assisting Russia and Belarus

October 5, 2022 By Bart M. McMillan and Lise S. Test 3 Mins Read

On September 30, 2022, the US Government imposed additional sanctions against Russia in response to Russia’s annexation of the Ukrainian provinces of Donetsk, Kherson, Luhansk, and Zaporizhzhya following referenda. New SDN Designations and OFAC FAQ The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced hundreds of new Russia-related designations to the Specially Designated Nationals and Blocked Persons List (“SDN List”). According to an accompanying press release, the designations include 14 individuals…

OFAC Amends Existing and Issues New General Licenses under Russia Sanctions to Authorize Pension Payments to Non-US Persons Outside of Russia and Closing Individual Accounts at Blocked Banks

August 29, 2022 By Bart M. McMillan, Alexandre (Alex) Lamy and Yu (Iris) Zhang 2 Mins Read

On August 19, 2022, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) replaced existing General License (“GL”) 38 with GL 38A and issued a new GL 50. These GLs authorize certain activities otherwise prohibited by EO 14024, which targets, among other things, specific sectors (including the financial services sector) of the Russian economy. Our prior blog post regarding EO 14024 and the financial sanctions imposed thereunder can be found here, here, here,…

BIS Announces New Policy Changes to Strengthen its Existing Administrative Enforcement Program

July 12, 2022 By Bart M. McMillan, Meghan Hamilton and Andrea Tovar 2 Mins Read

On June 30, 2022, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) announced four key policy changes to strengthen the administrative enforcement program and tackle external threats. These policy changes prioritize the “most serious violations” and cases that pose the greatest danger to US security. The four policy changes made to the BIS’s Administrative Enforcement Program include: Imposition of Significantly Higher Penalties The most serious administrative violations will trigger more stringent penalties…