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 11, 2022, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) imposed restrictions on the exports, reexports, and transfer of luxury goods to all end users in Russia and Belarus and to certain Russian and Belarusian oligarchs and malign actors located worldwide. This action is part of a new round of measures targeting Russia and Belarus announced by the White House today (see here and here) that are being implemented in…
As flagged in our initial blog, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) published on February 24, 2022 a public inspection copy of a final rule (“Final Rule”), effective immediately (subject to a very limited savings clause), that implements a sweeping series of export control measures under the Export Administration Regulations (“EAR”) against Russia. The press release regarding these new controls can be found here. The controls are a result of multi-laterally coordinated efforts…
The US Treasury Department’s Office of Foreign Assets Control (“OFAC”), the US State Department (“State”), and the US Commerce Department (“Commerce”) issued rules adjusting maximum civil monetary penalties (“CMPs”) under the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015 (“FCA”), as outlined below. (For additional years of CMPs, see our previous blog post available here.) OFAC CMP Adjustments Under OFAC’s final rule published on February 9, 2022, the adjusted penalties apply to CMPs…