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Alexandre (Alex) Lamy

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On May 9, 2022, the US Department of Commerce issued a Final Rule (the “Final Rule”) expanding the Russian industry sector sanctions to cover additional items subject to the Export Administration Regulations (the “EAR”) beyond restrictions targeting the Russian energy sector. Under the Russia industry sector sanctions, all items identified in Supplement No. 4 to part 746 of the EAR (“Supplement No. 4”) that are subject to the EAR trigger a licensing requirement when they…

On April 29, 2022 the US Department of Treasury’s Office of Foreign Assets Control (“OFAC”) announced the publication of a Final Rule that reissued and renamed the Ukraine-/Russia-Related Sanctions Regulations (“Reissued Regulations”) and updates to related public guidance. Found at 31 C.F.R. Part 589, the Reissued Regulations took effect on May 2 and have been expanded to include a more comprehensive set of regulations, including additional interpretive and definitional guidance, general licenses, and other regulatory…

In further US developments against Russia, (1) on April 19 and 20, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) targeted sanctions evaders, including by adding two Russian banks – Public Joint Stock Company Transkapitalbank (“TKB”) and its subsidiary, Joint Stock Company Investtradebank (“Investtradebank”) – and the virtual currency mining company, Bitriver AG and its subsidiaries, to the Specially Designated Nationals and Blocked Persons List (“SDN List”) for attempts to…

In a March 11 joint statement, the leaders of the G7 nations, consisting of Canada, France, Germany, Italy, Japan, the United Kingdom, and the United States, agreed to take action to deny Russia’s “most favored nation” status relating to key products of Russian companies. Likewise, they welcomed the ongoing preparation of a statement by a coalition of WTO members, including the G7, announcing their revocation of Russia’s “most favored nation” status. This statement also outlines…