On February 24, 2023, the US Government alongside G7 leaders announced via a White House statement a new set of trade and economic measures targeting Russia and Belarus and support for Ukraine. These measures were announced to mark the one-year anniversary of the Russian invasion of Ukraine and include the following: The US Treasury Department’s Office of Foreign Assets Control (“OFAC”) (i) issued a new determination authorizing the imposition of sanctions targeting the Russian metals…
On January 17, 2023, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) amended (i) certain Russia-related General Licenses (“GLs”) and (ii) four Russia-related Frequently Asked Questions (“FAQs”). Amended General Licenses Amended GLs include the following: GL 6C, “Transactions Related to Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates, the Coronavirus Disease 2019 (COVID-19) Pandemic, or Clinical Trials,” replaces and supersedes GL 6B (see previous blog post here)…
On June 30, 2022, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) announced four key policy changes to strengthen the administrative enforcement program and tackle external threats. These policy changes prioritize the “most serious violations” and cases that pose the greatest danger to US security. The four policy changes made to the BIS’s Administrative Enforcement Program include: Imposition of Significantly Higher Penalties The most serious administrative violations will trigger more stringent penalties…
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). We have outlined these developments in additional detail below. Additions of Russian and Belarusian Entities…