On March 7, 2022, the US Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued an alert to financial institutions warning about potential attempts to evade US sanctions and other restrictions imposed on Russia and Belarus (“Alert”). The Alert includes red flags that financial institutions should review to help identify potential attempts to avoid sanctions, with a particular focus on convertible virtual currency (“CVC”), and also reminds companies of their reporting obligations under the Bank Secrecy…
On 9 March, US Customs and Border Protection (CBP) issued guidance to implement Part A of the Office of Foreign Assets Control (OFAC) General License No. 16, Authorizing Transactions Related to Certain Imports Prohibited by Executive Order of 8 March 2022 Prohibiting Certain Imports and New Investments With Respect to Continued Russian Federation Efforts to Undermine the Sovereignty and Territorial Integrity of Ukraine (“GL16”). GL16 expires at 12:01 am Eastern daylight time on 22 April…
On February 28, 2022, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued a number of additional sanctions measures against Russia. The latest measures include the issuance of (i) Russia-related Directive 4 (“Directive 4”), expanding restrictions on Russian state-controlled financial instructions under the April 2021 Executive Order 14024 (“EO 14024”) and (ii) Russia-related General License No. 8A (“GL 8A”), amending and replacing previous General License No. 8. OFAC also added key Russian state-controlled…
On February 23, 2022, as “another piece of [the US government’s] initial tranche of sanctions in response to Russia’s actions in Ukraine,” the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) designated Nord Stream 2 AG, the Swiss company in charge of building Russia’s Nord Stream 2 gas pipeline, and its German chief executive officer, Matthias Warnig, to OFAC’s List of Specially Designated Nationals and Blocked Persons. The sanctions on Nord Stream 2 follow…