The Middle East is an increasingly important jurisdiction for Western governments from a Russia sanctions foreign policy perspective, as there is a perception that increased trade flows between the Middle East and Russia means that Western sanctions are effectively being circumvented. Companies in the Middle East may have concerns about triggering EU / UK / US sanctions jurisdiction, or being directly designated by Western governments for engaging in activities deemed to be contrary to the…
On June 12, 2024, the US Departments of Treasury and Commerce issued new sanctions and export controls in response to Russia’s continued war in Ukraine. Below we outline key categories of these new and expanded trade measures designed to restrict the flow of support to the Russian military-industrial base. The new sanctions issued by the US Department of Treasury’s Office of Foreign Assets Control (“OFAC”) are directed at Russia’s foundational financial infrastructure and access to…
On May 28, 2024, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) amended the Cuban Assets Control Regulations (“CACR”) and issued new and updated frequently asked questions (“FAQs”) to further implement a policy originally announced by the Biden Administration on May 16, 2022 to increase support for the Cuban people and private sector entrepreneurs. The CACR has been revised as follows: OFAC has also issued six new CACR FAQs (1174–1179) and amended eight…
The US and UK introduced new prohibitions last month related to Russian-origin aluminum, copper, and nickel produced on or after April 13, 2024. The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued two determinations imposing new restrictions on the importation of Russian-origin aluminum, copper, and nickel produced on or after to April 13, 2024 (the “Covered Russian Metals”) into the United States, and on the provision by US persons or within…