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…
On July 14, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) reissued three Russia-related General Licenses (“GLs”) and issued one new one. OFAC also amended FAQs 967, 1,039, and 1,040, with changes mostly relating to updates made within the GLs. OFAC also issued a new fact sheet on “Russia Sanctions and Agricultural Trade.” GL 6B was amended to broaden the scope of authorized activities in three ways: (i) to broaden…
On June 27, 2022, President Biden and the other G7 leaders issued a statement on support for Ukraine (“G7 Statement”), in which they vowed to sustain and intensify their coordinated sanctions measures in response to Russia’s war of aggression. The corresponding White House Announcement outlines the actions the Biden Administration planned to take in coordination with the G7, including additional sanctions measures. The following day, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”)…