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On June 12, 2024, the US Departments of Treasury and Commerce issued new sanctions and export controls in response to Russia’s continued war in Ukraine. Below we outline key categories of these new and expanded trade measures designed to restrict the flow of support to the Russian military-industrial base. The new sanctions issued by the US Department of Treasury’s Office of Foreign Assets Control (“OFAC”) are directed at Russia’s foundational financial infrastructure and access to…

On September 18, 2023, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) established a new humanitarian channel (“HC”) in Qatar to facilitate the provision of humanitarian assistance to the Iranian people. The HC is similar to humanitarian channels established under previous administrations and is designed to help the Iranian people gain access to food, agricultural goods, medicine, and medical devices, while ensuring that funds are not misused and is intended…

On January 17, 2023, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) amended (i) certain Russia-related General Licenses (“GLs”) and (ii) four Russia-related Frequently Asked Questions (“FAQs”). Amended General Licenses Amended GLs include the following: GL 6C, “Transactions Related to Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates, the Coronavirus Disease 2019 (COVID-19) Pandemic, or Clinical Trials,” replaces and supersedes GL 6B (see previous blog post here)…

On December 15, 2022, the United States Department of the Treasury’s Office of Foreign Assets Control (ā€œOFACā€) added Public Joint Stock Company Rosbank (ā€œRosbankā€) and 17 subsidiaries of VTB Bank Public Joint Stock Company (“VTB Bank”) to the Specially Designated Nationals and Blocked Persons List (ā€œSDN Listā€). The United States Department of State (ā€œState Departmentā€) designated Vladimir Potanin, three members of his family, and his company Interros, pursuant to Executive Order 14024, with the result…