On December 29, 2016, the US government announced several measures in response to the Russian government’s alleged “aggressive harassment of U.S. officials and cyber operations aimed at the U.S. election.” The measures impose sanctions against nine Russian parties, including the Russian Federal Security Service (“FSS” or “FSB”). In addition, the US government announced the expulsion of 35 Russian diplomats from the United States and the closing of two US properties for their alleged intelligence operations. As a result of the sanctions, US companies will now likely require US government authorization prior to dealing with the FSB, which can include submissions to or the receipt of approvals from the FSB to market or distribute certain encryption products in Russia or participation in certain other regulatory actions before the FSB.
On December 22, 2015, the US Office of Foreign Assets Control (“OFAC”) announced that it had added 34 parties (i.e., 12 individuals and 22 entities) to the Specially Designated Nationals and Blocked Persons List (“SDN List”) and 86 entities to the Sectoral Sanctions Identifications List (“SSI List”) under the US Government’s Russia/Ukraine-related Sanctions Program. In a press release, OFAC stated that these designations are part of its continued efforts to counter attempts to circumvent US Russia/Ukraine-related sanctions, to further align US sanctions…
On 2 September 2015, the US Commerce Department’s Bureau of Industry and Security (“BIS”) amended the Export Administration Regulations (“EAR”) to add 29 parties to the Entity List for violating international law and fueling the conflict in eastern Ukraine. The additions were made to ensure the efficacy of existing US sanctions on Russia. The 29 parties are located in the Crimea region of Ukraine, Cyprus, Finland, Romania, Romania, Russia, Switzerland, Ukraine, and the United Kingdom…
On 7 August 2015, the U.S. Commerce Department’s Bureau of Industry and Security (“BIS”) published a final rule adding a Russian oil and gas field, the Yuzhno-Kirinskoye Field located in the Sea of Okhotsk, to the Entity List maintained in the Export Administration Regulations, 15 C.F.R. Parts 730-774 (“EAR”). As a result of this designation, the exportation, reexportation, or in-country transfer to this field of any item subject to the EAR requires a BIS…