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Callie Lefevre

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

On October 6, 2022, the Assistant Secretary for Export Enforcement issued a policy aimed at enhancing enforcement of the antiboycott rules administered by the US Department of Commerce (“Commerce”). The following day a final rule came into effect updating Commerce’s guidance on charging and penalty determinations related to violations of the antiboycott provisions of the Export Administration Regulations (the “EAR”). The changes are intended to bring penalty determinations in line with Commerce’s current view of…

On April 28, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued a final rule amending and reissuing the Somalia Sanctions Regulations, 31 C.F.R. Part 551 (“Regulations”) to further implement two existing Executive Orders, Executive Order 13536 of April 2010 and Executive Order 13620 of July 2012, and to replace the prior Somalia Sanctions Regulations that were published in May 2010 in abbreviated form. The Regulations also add a number of definitions…

On April 8, 2021, the US Treasury Department published an updated List of Countries Requiring Cooperation With An International Boycott (the “Treasury List”). Significantly, Treasury announced that it had removed the UAE from the Treasury List following the UAE’s repeal of its law requiring participation with the Arab League Boycott of Israel and subsequent implementation of the new policy. In connection with its establishment of full diplomatic ties with Israel last year under the UAE-Israel…