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Callie Lefevre

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On March 14, 2024, the U.S. Department of Stateā€™s Directorate of Defense Trade Controls (ā€œDDTCā€) and the U.S. Department of Commerceā€™s Bureau of Industry and Security (ā€œBISā€) announced more restrictive export controls on Nicaragua stated to be in response to the Nicaraguan Governmentā€™s human rights abuses, attacks on civil society, and increased cooperation with Russia. The DDTC and BIS press releases are available here and here. DDTC: New ITAR Export Controls The State Department announced…

On April 27, 2023, the US Department of State (ā€œStateā€) designated Russiaā€™s Federal Security Service (ā€œFSBā€) and Iranā€™s Islamic Revolutionary Guard Corps Intelligence Organization (ā€œIRGC-IOā€) pursuant to Executive Order (ā€œEOā€) 14078 (Bolstering Efforts To Bring Hostages and Wrongfully Detained United States Nationals Home), with the result that the IRGC-IO has been added to the Specially Designated Nationals and Blocked Persons List (ā€œSDN Listā€). The IRGC as a whole and FSB were previously designated on the…

On January 25, 2023, the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued an alert to financial institutions regarding potential investments in the US commercial real estate (“CRE”) sector by sanctioned Russian individuals, their family members, and entities through which they act (“Alert”). The Alert complements an earlier alert that FinCEN issued in March 2022, shortly after Russia invaded Ukraine. Our coverage of the March 2022 alert can be found here. In…

On December 15, 2022, the United States Department of the Treasury’s Office of Foreign Assets Control (ā€œOFACā€) added Public Joint Stock Company Rosbank (ā€œRosbankā€) and 17 subsidiaries of VTB Bank Public Joint Stock Company (“VTB Bank”) to the Specially Designated Nationals and Blocked Persons List (ā€œSDN Listā€). The United States Department of State (ā€œState Departmentā€) designated Vladimir Potanin, three members of his family, and his company Interros, pursuant to Executive Order 14024, with the result…