On May 2 and 5, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued three new and two amended Russia-related General Licenses (“GLs”). OFAC also issued one new Frequently Asked Question (“FAQ”) and amended another. Additionally, Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a tranche of Russia-related FAQs. New General Licenses GL 30 authorizes all transactions involving Gazprom Germania GmbH that are prohibited by Directive 3 under…
On February 2, 2022, the US Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued seven new Frequently Asked Questions (“FAQs”) (FAQs 957 through 963) and on February 25, 2022, issued General License 20, “Authorizing Transactions Involving Afghanistan or Governing Institutions in Afghanistan” (“GL 20”) to expand authorizations for commercial and financial transactions in Afghanistan and seven new FAQs (FAQs 991 through 997). OFAC also made updates to FAQs to account for the new…
US Senate Democrats, with support from the White House, have introduced the Defending Ukraine Sovereignty Act of 2022 (S. 3488). This bill seeks to deter a Russian “escalation” of hostilities in or against Ukraine through the threat of imposing sanctions against Russian officials and companies, as well as individuals and entities involved in the Nord Stream 2 pipeline. The bill currently has 41 cosponsors, all Democrats, so they will need to find Republican support for…
On January 25, 2022, two senior Biden Administration officials held a background press call on potential economic deterrence measures to be imposed in the event of a Russian invasion of Ukraine. The senior officials stated that, if that happens, the US Government is prepared to impose sanctions with “massive consequences” for Russia that were not previously considered following the 2014 annexation of Crimea. The senior officials said that any new sanctions would be much stronger…