Accounting, Trust and Corporate Formation, and Management Consulting Services Ban On May 8, 2022, the US Department of Treasury’s Office of Foreign Assets Control (“OFAC”), in consultation with the US Department of State, issued a Determination Pursuant to Section 1(a)(ii) of Executive Order 14071 (“EO 14071 Determination”) determining that the prohibitions under Section (1)(a)(ii) of Executive Order (“EO”) 14071 (our previous blog regarding EO 14071 can be found here) shall apply to accounting, trust and…
On March 18, 2022 and in response to Russia’s invasion of Ukraine, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) publicly identified 100 commercial and private aircraft that have recently flown into Russia in apparent violation of the Export Administration Regulations (“EAR”). As summarized in our prior blog posts (see here and here), the US has also issued restrictions that effectively ban any aircraft with a nexus to Russia from using US…
On March 2, 2022, in response to Belarus’s enabling of Russia’s further invasion of Ukraine, the US Commerce Department’s Bureau of Industry and Security (“BIS”) issued a final rule (“Final Rule”) effective on the same day, that implements sweeping export controls measures targeting Belarus. This Final Rule subjects Belarus to substantially the same export controls that were imposed on Russia and became effective on February 24, 2022. (Our blog post summarizing those export controls targeting…
On February 23, 2022, as “another piece of [the US government’s] initial tranche of sanctions in response to Russia’s actions in Ukraine,” the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) designated Nord Stream 2 AG, the Swiss company in charge of building Russia’s Nord Stream 2 gas pipeline, and its German chief executive officer, Matthias Warnig, to OFAC’s List of Specially Designated Nationals and Blocked Persons. The sanctions on Nord Stream 2 follow…