On January 5, 2023, the US and Turkish governments took joint action imposed sanctions targeting four individuals and two entities determined to be associated with the financial facilitation network of the Islamic State of Iraq and Syria (“ISIS”). See here for the US action and here for the Turkish action. The designations target the Islamic State group’s head of foreign financing, Abd Al Hamid Salim Ibrahim Ismail Brukan al-Khatuni, and his network coordinated by his sons.…
On December 30, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued “Preliminary Guidance on Implementation of the Price Cap Policy for Petroleum Products of Russian origin” to explain how OFAC will implement a ban on the provision of services related to the maritime transportation of Russian-origin petroleum products (“Petroleum Products Guidance”). The petroleum products ban builds on a similar ban related to maritime transportation of Russian-origin crude oil that…
On December 16, 2022, the US Department of State’s Directorate of Defense Trade Controls (“DDTC”) issued a proposed rule that would treat two additional types of transactions as activities that are not exports, reexports, retransfers, or temporary imports (“controlled events”) (and, thus, not require authorization) under the International Traffic in Arms Regulations (“ITAR”). The two additional activities that would not constitute controlled events are: Taking defense articles outside a previously approved country by the armed…
On December 15, 2022, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) added Public Joint Stock Company Rosbank (“Rosbank”) and 17 subsidiaries of VTB Bank Public Joint Stock Company (“VTB Bank”) to the Specially Designated Nationals and Blocked Persons List (“SDN List”). The United States Department of State (“State Department”) designated Vladimir Potanin, three members of his family, and his company Interros, pursuant to Executive Order 14024, with the result…