Last week, among the flurry of new sanctions announcements marking the one-year anniversary of Russia’s large-scale invasion of Ukraine, the G7 announced the creation of a new Enforcement Coordination Mechanism “to bolster compliance and enforcement of our measures and deny Russia the benefits of G7 economies.” The International Group of Seven (“G7”) is an intergovernmental forum whose members include the US, UK, Germany, France, Italy, Canada, and Japan, with the European Union as a “non-enumerated”…
On February 9, 2023, the United States and the United Kingdom designated seven Russian individuals that have been associated with the development or deployment of a range of ransomware strains which have targeted the UK and the US. This is the first time that the UK has made designations under its Cyber (Sanctions) (EU Exit) Regulations 2020. The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued this press release in tandem…
On January 25, 2023, the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued an alert to financial institutions regarding potential investments in the US commercial real estate (“CRE”) sector by sanctioned Russian individuals, their family members, and entities through which they act (“Alert”). The Alert complements an earlier alert that FinCEN issued in March 2022, shortly after Russia invaded Ukraine. Our coverage of the March 2022 alert can be found here. In…
On January 26, 2023, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) redesignated PMC Wagner (“Wagner Group”) a Significant Transnational Criminal Organization (“STCO”) pursuant to Executive Order 13581 (“EO 13581”) as amended by Executive Order 13863 (“EO 13863”) for the Wagner Group’s activities in Ukraine, the Central African Republican (“CAR”), and Mali. Concurrently, OFAC has sanctioned the Wagner Group under Executive Order 13667 (“EO 13667”) for its activities in the CAR.…