Just before the holidays, President Biden signed two bills passed in the final days of the last Congress that contain a number of provisions with implications for sanctions, export controls, and supply chain restrictions: On December 23, 2022, President Biden signed into law the National Defense Authorization Act (“NDAA”) for Fiscal Year 2023 (P.L. 117-263). The measure includes a number of provisions relating to US export controls, sanctions, and related subjects, including additional sanctions targeting…
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…
On November 22, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published a new determination pursuant to Executive Order 14071 of April 6, 2022 (“EO 14071”) – “Determination Pursuant to Section 1 (a)(ii) of EO 14071” (“Determination”). The Determination implements the price cap policy for Russian crude oil, as anticipated based on OFAC’s September 2022 preliminary guidance related to the implementation of the policy banning the provision of services related to…
On July 14, 2022, the U.S. House of Representatives passed the National Defense Authorization Act for Fiscal Year 2023 (“NDAA”). One of the amendments included in the House-passed version of the NDAA is a revised version of the “Federal Contracting For Peace And Security Act.” The amendment would prohibit the federal government from entering into, extending, or renewing contracts with contractors that conduct business operations in Russia during its war against Ukraine, with certain exceptions…