On March 14, 2024, the U.S. Department of Stateās Directorate of Defense Trade Controls (āDDTCā) and the U.S. Department of Commerceās Bureau of Industry and Security (āBISā) announced more restrictive export controls on Nicaragua stated to be in response to the Nicaraguan Governmentās 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 (āStateā) designated Russiaās Federal Security Service (āFSBā) and Iranās Islamic Revolutionary Guard Corps Intelligence Organization (āIRGC-IOā) pursuant to Executive Order (āEOā) 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 (āSDN 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 (āOFACā) added Public Joint Stock Company Rosbank (āRosbankā) and 17 subsidiaries of VTB Bank Public Joint Stock Company (“VTB Bank”) to the Specially Designated Nationals and Blocked Persons List (āSDN Listā). The United States Department of State (āState Departmentā) designated Vladimir Potanin, three members of his family, and his company Interros, pursuant to Executive Order 14024, with the result…