Today, the US Department of State issued a press release indicating that the US Government will be imposing new sanctions on Russia for the use of a “Novichok” nerve agent in an attempt to assassinate UK citizen Sergei Skripal and his daughter Yulia Skripal, based on its August 6, 2018, determination under the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (“CBW Act”) that the Russian Government has used chemical or biological weapons in violation of international law or has used lethal chemical or biological weapons against its own nationals. The CBW Act requires the President to impose sanctions on a foreign country with respect to which such a determination has been made.
The Russian government is preparing to introduce new counter-measures in response to US and EU sanctions. Draft Bill on Russian Countermeasures Last week the State Duma decided to amend Draft Bill No. 441399-7 “On Measures (Countermeasures) in Response to Unfriendly Actions of the USA and (or) other Foreign States” (“Draft on Countermeasures”). As opposed to the initial version of the Draft on Countermeasures, the new version proposes the following five measures: Termination or suspension of international cooperation…
On May 1, 2018, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued General License 12B (“GL 12B”) and General License 13A (“GL 13A”), replacing and superseding in their entirety General License 12A (“GL 12A”) and General License 13 (“GL 13”), respectively. These expanded general licenses are intended to relieve some of the challenges faced by US persons, including US financial institutions, in winding down activities with and divesting interests in certain targeted Russian Specially Designated Nationals (“SDNs”). Please see our prior blog posts concerning (i) the designation of certain Russian oligarchs, government officials, and entities, and the initial issuance of General License 12 and GL 13 here and (ii) the issuance of GL 12A and General License 14 here.
On April 23, 2018, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued General License No. 14 (“GL 14”) related to United Company RUSAL PLC (“RUSAL”), to supplement and expand an existing authorization under General License No. 12A (“GL 12A”). GL 14 authorizes US persons to engage in specified transactions ordinarily incident and necessary to the maintenance or winding down of operations, contracts, or other agreements that were in effect prior to April 6, 2018, and that involve RUSAL or any entity in which it owns a 50% or greater interest (together, “RUSAL Entities”). GL 14 is valid until October 23, 2018. Along with GL 14, OFAC also issued updated FAQs.