On June 2, 2022, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) added additional Russian and Belarussian entities to the BIS Entity List, enacted new licensing requirements for food, medicine for military end-users on the Entity List, and stated that they would be making charging letters public in a pair of Final Rules (here and here).Ā We have outlined these developments in additional detail below. Ā Additions of Russian and Belarusian Entities…
On May 12, 2022, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued Syria General License No. 22 (“GL 22”), authorizing certain activities in particular sectors of the Syrian economy that are otherwise prohibited under the Syrian Sanctions Regulations (31 CFR Part 542, “SSR”) in specified regions of Syria not controlled by the Assad regime. According to the US Statement Department’s press release, GL 22 was issued in support of the Biden Administration’s…
On April 25, 2022, the US Treasury Departmentās Office of Foreign Assets Control (āOFACā) re-issued General License 13R (āGL 13Rā) and General License 15L (āGL 15Lā), narrowing those authorized activities with GAZ Group and entities owned 50% or more by GAZ Group (āGAZā), as further described below. OFAC also issued a set of updated FAQs to clarify the scope of authorized activities under these GLs. Our most recent blog post on these GLs is available…
On February 22, 2022, the US Government issued a number of additional sanctions measures against Russia in response to President Putin’s recognition of the independence of the “so-called Donetsk People’s Republic (DNR) and Luhansk People’s Republic in Ukraine (LNR)” and his request to deploy forces to those regions – with President Biden characterizing these developments as “the beginning of a Russian invasion of Ukraine.” The new US sanctions measures build on the comprehensive region-wide sanctions…