On November 22, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published a new determination pursuant to Executive Order 14071 of April 6, 2022 (“EO 14071”) – “Determination Pursuant to Section 1 (a)(ii) of EO 14071” (“Determination”). The Determination implements the price cap policy for Russian crude oil, as anticipated based on OFAC’s September 2022 preliminary guidance related to the implementation of the policy banning the provision of services related to…
On September 15, 2022, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule (the “Final Rule”) to expand the existing sanctions against Russia and Belarus under the Export Administration Regulations (“EAR”). The purpose of the Final Rule is to “protect U.S. national security and foreign policy interests by further restricting Russia’s access to items that it needs to support its military capabilities.” The Final Rule took effect on September…
On July 22, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued two new Russia-related general licenses (“GLs”), published two new FAQs regarding these GLs, and amended two existing Russia-related FAQs. The new GLs authorize certain activities related to Russian bonds and securities and appear intended solely to help US investors wind down their financial exposure to Russia and settle certain credit default swaps following Russia’s recent June default on…
On June 2, 2022, the US Government increased sanctions against Russia in stated response to Russian attempts to evade US sanctions, including targeting additional government officials, business leaders and luxury assets. The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a new round of Russia -related designations to the Specially Designated Nationals and Blocked Persons List (“SDN List”). OFAC also amended one existing general license (“GL”), issued two wind-down general licenses,…