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SDN List

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In the past several days, the US Government has issued a slew of sanctions measures targeting Russia. These represent the first major escalation of sanctions against Russia under the Biden Administration and, according to a White House Fact Sheet , are stated to be in response to Russia’s “harmful foreign activities,” including efforts to undermine free and fair democratic elections and institutions, malicious cyber activities (including the recent SolarWinds incident), transnational corruption, targeting of dissidents…

Under the Russian encryption regulations, notification to, or registration with, the Russian Federal Security Service (the “FSB”) is required in order to import and distribute foreign products (hardware and software) with encryption functions or features in the Russian Federation. Although the FSB is a sanctioned party, listed on the Office of Foreign Assets Control (“OFAC”) list of specially designated nationals and blocked persons (the “OFAC SDN List”) pursuant to the Cyber-Related Sanctions Regulations, 31 C.F.R.…

On April 1, 2021, President Biden revoked Executive Order 13928 “Blocking Property of Certain Persons Associated with the International Criminal Court” (the “ICC EO”), which authorized the imposition of sanctions and visa restrictions on non-US ICC officials. The US Treasury Department’s Office of Foreign Assets Control concurrently removed two senior ICC officials from the Specially Designated Nationals and Blocked Persons List (“SDN List”), including Fatou Bensouda, the ICC’s chief prosecutor. The ICC EO was signed…

On February 16, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) removed Ansarallah, a political movement and militia group in Yemen also known as the Houthis, from the Specially Designated Nationals and Blocked Persons List (“SDN List”). Ansarallah had been added to the SDN List on January 19, 2021, as a Foreign Terrorist Organization (“FTO”) and Specially Designated Global Terrorist (“SDGT”). As a result of the removal, US Persons no longer require…