On September 30, 2022, the US Government imposed additional sanctions against Russia in response to Russia’s annexation of the Ukrainian provinces of Donetsk, Kherson, Luhansk, and Zaporizhzhya following referenda. New SDN Designations and OFAC FAQ The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced hundreds of new Russia-related designations to the Specially Designated Nationals and Blocked Persons List (“SDN List”). According to an accompanying press release, the designations include 14 individuals…
On September 15, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued (i) two new Determinations under Executive Order (“EO”) 14024; (ii) two new Russia-related General Licenses (“GLs”); (iii) seven new Frequently Asked Questions (“FAQs”) and (iv) five amended FAQs. A press release was issued in tandem with these actions. New Determinations under EO 14024 The new Determination Pursuant to Section 1(a)(i) of Executive Order 14024 expands authorities for the…
Following initial announcements last year, on July 20, 2022, the US Department of State’s Directorate of Defense Trade Controls (“DDTC”) published two Open General Licenses (“OGLs”) permitting certain reexports and retransfers to certain parties under the International Trade in Arms Regulations (“ITAR”). The OGLs, which are part of a DDTC pilot program, will be valid for one year, effective from August 1, 2022 through July 31, 2023. The related DDTC fact sheet can be found…
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…