On March 18, 2022 and in response to Russia’s invasion of Ukraine, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) publicly identified 100 commercial and private aircraft that have recently flown into Russia in apparent violation of the Export Administration Regulations (“EAR”). As summarized in our prior blog posts (see here and here), the US has also issued restrictions that effectively ban any aircraft with a nexus to Russia from using US…
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…