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US Export Controls

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On June 27, 2022, President Biden and the other G7 leaders issued a statement on support for Ukraine (“G7 Statement”), in which they vowed to sustain and intensify their coordinated sanctions measures in response to Russia’s war of aggression. The corresponding White House Announcement outlines the actions the Biden Administration planned to take in coordination with the G7, including additional sanctions measures. The following day, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”)…

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…

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 21, 2022, the White House issued a new Executive Order that imposes comprehensive sanctions on the so-called Donetsk People’s Republic (“DNR”) and Luhansk People’s Republic (“LNR”) regions of Ukraine. Concurrently with the issuance of the Executive Order, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) published six general licenses (“GLs”) authorizing certain transactions involving the targeted regions. These sanctions were imposed in response to the Russian Government’s decision to recognize the…