Introduction During September 2023, the US, UK, and EU, and Japan, updated their Common High Priority Items Lists (“the List(s)”), with seven new Harmonized System (“HS”) codes. These coordinated Lists are composed of items identified as critical to Russia’s war effort, weapons systems and military development. The Lists highlight to businesses that there is a particularly high risk these sanctioned items may be the target of sanctions circumvention and possible diversion to Russia. Companies can…
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 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”)…
On March 11, 2022, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) imposed restrictions on the exports, reexports, and transfer of luxury goods to all end users in Russia and Belarus and to certain Russian and Belarusian oligarchs and malign actors located worldwide. This action is part of a new round of measures targeting Russia and Belarus announced by the White House today (see here and here) that are being implemented in…