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Kerry B. Contini

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On February 9, 2023, the United States and the United Kingdom designated seven Russian individuals that have been associated with the development or deployment of a range of ransomware strains which have targeted the UK and the US. This is the first time that the UK has made designations under its Cyber (Sanctions) (EU Exit) Regulations 2020. The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued this press release in tandem…

On February 9, 2023, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Syria General License 23, “Authorizing Transactions Related to Earthquake Relief Efforts in Syria.” General License 23 authorizes transactions related to earthquake relief efforts in Syria that would otherwise be prohibited by the Syrian Sanctions Regulations (“SySR”) through 12:01 p.m. eastern daylight time, August 8, 2023. General License 23 does not authorize importation of petroleum or petroleum products of…

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…

Just before the holidays, President Biden signed two bills passed in the final days of the last Congress that contain a number of provisions with implications for sanctions, export controls, and supply chain restrictions: On December 23, 2022, President Biden signed into law the National Defense Authorization Act (“NDAA”) for Fiscal Year 2023 (P.L. 117-263). The measure includes a number of provisions relating to US export controls, sanctions, and related subjects, including additional sanctions targeting…