On June 6, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published new and amended Frequently Asked Questions (“FAQs “) regarding the Russian investment ban imposed under Executive Orders 14066, 14068, and 14071 (collectively, the “Investment Ban EOs”). Our prior blog posts on these Investment Ban EOs can be found here and here. These new and amended FAQs define the term “new investment” used in the Investment Ban EOs and…
Accounting, Trust and Corporate Formation, and Management Consulting Services Ban On May 8, 2022, the US Department of Treasury’s Office of Foreign Assets Control (“OFAC”), in consultation with the US Department of State, issued a Determination Pursuant to Section 1(a)(ii) of Executive Order 14071 (“EO 14071 Determination”) determining that the prohibitions under Section (1)(a)(ii) of Executive Order (“EO”) 14071 (our previous blog regarding EO 14071 can be found here) shall apply to accounting, trust and…
On April 6, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) added two of Russia’s largest banks, Public Joint Stock Company Sberbank of Russia (“Sberbank”) and Joint Stock Company Alfa Bank (“Alfa-Bank”), and their subsidiaries to the Specially Designated Nationals and Blocked Persons List (“SDN List”). OFAC also issued 3 new and 3 amended Russia-related General Licenses, and added several other parties to the SDN List. President Biden also issued…
On March 11, 2022, the US Government issued a number of additional sanctions measures against Russia. The latest measures include the issuance of (i) a new Russia-related Executive Order 14068, “Executive Order on Prohibiting Certain Imports, Exports, and New Investment with Respect to Continued Russian Federation Aggression” (“EO 14068”) and (ii) four new General Licenses (“GLs”) related to Russia and Ukraine. These measures include a ban on exports and sales of a range of luxury…