Trade Law
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The United Kingdom just issued a new statutory instrument, effective immediately, which extends the authority to designate persons and entities under the
U.K. sanctions against Russia.
U.K. sanctions against Russia.
Trade Law
On February 2, 2017, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Cyber-related General License (GL) 1, a general
license that authorizes certain transactions with Russia’s Federal Security Service (Federalnaya Sluzhba Bezopasnosti or FSB). GL 1 authorizes U.S. persons
(i.e., individuals and companies) to request, receive, use, pay for or deal in licenses, permits, certifications, or notifications issued or registered by the FSB for
information technology (IT) products in Russia, provided that (i) the relevant IT goods or technology are subject to the U.S. Export Administration Regulations
(EAR) and are licensed or otherwise authorized by the U.S. Department of Commerce’s Bureau of Industry and Security (BIS); and (ii) payment of fees to the
FSB for such licenses and other authorization or notification does not exceed $5,000 in any calendar year. GL 1 also authorizes transactions or activities that
are necessary and ordinary incident to complying with law enforcement or administrative actions or investigations involving the FSB or rules and regulation...
license that authorizes certain transactions with Russia’s Federal Security Service (Federalnaya Sluzhba Bezopasnosti or FSB). GL 1 authorizes U.S. persons
(i.e., individuals and companies) to request, receive, use, pay for or deal in licenses, permits, certifications, or notifications issued or registered by the FSB for
information technology (IT) products in Russia, provided that (i) the relevant IT goods or technology are subject to the U.S. Export Administration Regulations
(EAR) and are licensed or otherwise authorized by the U.S. Department of Commerce’s Bureau of Industry and Security (BIS); and (ii) payment of fees to the
FSB for such licenses and other authorization or notification does not exceed $5,000 in any calendar year. GL 1 also authorizes transactions or activities that
are necessary and ordinary incident to complying with law enforcement or administrative actions or investigations involving the FSB or rules and regulation...
Trade Law
Overview of Actions Taken by the United States On December 29, 2016, President Obama announced that he was sanctioning nine individuals and entities:
the Main Intelligence Directorate (aka Glavnoe Razvedyvatel’noe Upravlenie) (GRU) and the Federal Security Service (aka Federalnaya Sluzhba Bezopasnosti)
(FSB), two Russian intelligence services; four individual officers of the GRU; and three companies that were stated to have provided material support to the
GRU’s cyber operations. In addition, two Russian individuals were sanctioned for using cyber-enabled means to cause misappropriation of funds and personal
identifying information. These actions mark the first expansion of the Specially Designated Nationals (SDN) List to include entities and individuals under the
U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) cybersecurity program since it was established on April 1, 2015. The 2015 client alert
can be found here.
the Main Intelligence Directorate (aka Glavnoe Razvedyvatel’noe Upravlenie) (GRU) and the Federal Security Service (aka Federalnaya Sluzhba Bezopasnosti)
(FSB), two Russian intelligence services; four individual officers of the GRU; and three companies that were stated to have provided material support to the
GRU’s cyber operations. In addition, two Russian individuals were sanctioned for using cyber-enabled means to cause misappropriation of funds and personal
identifying information. These actions mark the first expansion of the Specially Designated Nationals (SDN) List to include entities and individuals under the
U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) cybersecurity program since it was established on April 1, 2015. The 2015 client alert
can be found here.
Trade Law
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued new Russia/Ukraine-related sanctions on Thursday, September 1, 2016.
This action marks OFAC’s first major expansion of the Specially Designated Nationals (SDN) List and Sectoral Sanctions Identifications (SSI) List for the Russia
sanctions program since December 22, 2015. Additionally, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) made corresponding
additions to its Entity List on September 7, 2016.
This action marks OFAC’s first major expansion of the Specially Designated Nationals (SDN) List and Sectoral Sanctions Identifications (SSI) List for the Russia
sanctions program since December 22, 2015. Additionally, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) made corresponding
additions to its Entity List on September 7, 2016.
Trade Law
U.S. Department of Commerce Places Export Restrictions on 29 Parties; State Department Announces Sanctions on Russian Defense Companies; EU to
Extend Russia-Related Sanctions. A. BIS Adds 29 Entities to Entity List On September 2, 2015, the U.S. Department of Commerce’s Bureau of Industry and
Security (BIS) issued a final rule amending the Export Administration Regulations (EAR) by adding
29 parties to its Entity List, a restricted-party list identifying foreign persons that engage in activities contrary to U.S. national security and/or foreign policy
interests. This latest action was taken in accordance with Executive Orders 13660, 13661, 13662 and 13685 to “ensure the efficacy of existing sanctions on
[Russia] for violating international law and fueling the conflict in Ukraine.” For 14 of the 29 entities added to the Entity List, BIS imposes a general license
requirement for all items subject to the EAR. Accordingly, all exports, re-exports and transfers (in-country) of all restricted items to these companies require...
Extend Russia-Related Sanctions. A. BIS Adds 29 Entities to Entity List On September 2, 2015, the U.S. Department of Commerce’s Bureau of Industry and
Security (BIS) issued a final rule amending the Export Administration Regulations (EAR) by adding
29 parties to its Entity List, a restricted-party list identifying foreign persons that engage in activities contrary to U.S. national security and/or foreign policy
interests. This latest action was taken in accordance with Executive Orders 13660, 13661, 13662 and 13685 to “ensure the efficacy of existing sanctions on
[Russia] for violating international law and fueling the conflict in Ukraine.” For 14 of the 29 entities added to the Entity List, BIS imposes a general license
requirement for all items subject to the EAR. Accordingly, all exports, re-exports and transfers (in-country) of all restricted items to these companies require...
Trade Law
On August 7, 2015, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published a final rule adding the Yuzhno-Kirinskoye Field, a
Russian oil and gas field located in the Sea of Okhotsk, to its Entity List, a restricted party list maintained by BIS which identifies foreign persons that engage
in activities contrary to U.S. national security and/or foreign policy interests. Consequently, exports, reexports and transfers (in-country) of all items subject to
the Export Administration Regulations (EAR) to this Russian field require a license from BIS. Furthermore, BIS will consider such license requests with a
presumption of denial.
Russian oil and gas field located in the Sea of Okhotsk, to its Entity List, a restricted party list maintained by BIS which identifies foreign persons that engage
in activities contrary to U.S. national security and/or foreign policy interests. Consequently, exports, reexports and transfers (in-country) of all items subject to
the Export Administration Regulations (EAR) to this Russian field require a license from BIS. Furthermore, BIS will consider such license requests with a
presumption of denial.
Trade Law
On July 30, 2015, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a Crimea Sanctions Advisory highlighting certain
practices that have been used to circumvent or evade U.S. sanctions involving Crimea and suggesting measures to mitigate Crimea sanctions risks.
practices that have been used to circumvent or evade U.S. sanctions involving Crimea and suggesting measures to mitigate Crimea sanctions risks.
Trade Law
Signaling increased tensions with Russia regarding its alleged intervention in eastern Ukraine, the European Union on June 19 and 22, 2015, took action
extending sanctions targeting Russia and Crimea, including measures that prohibit EU persons from investing in or importing from Crimea and measures that
restrict certain companies operating in Russia’s energy, defense and financial sectors from accessing European capital and equity markets.
extending sanctions targeting Russia and Crimea, including measures that prohibit EU persons from investing in or importing from Crimea and measures that
restrict certain companies operating in Russia’s energy, defense and financial sectors from accessing European capital and equity markets.
Trade Law
On Saturday, the U.S. Congress passed the Ukraine Freedom Support Act of 2014 (H.R. 5859), which, once signed by the president, will impose or authorize
broad sanctions on Russia’s energy and defense sectors and increase military and nonmilitary assistance to Ukraine.White House officials have indicated that
the President is expected to sign the legislation into law. The legislation includes a mix of mandatory and discretionary sanctions that could significantly
discourage investment in, and transactions with, Russia’s energy and defense sectors. The legislation also authorizes extraterritorial sanctions aimed at
foreign financial institutions that facilitate certain sanctionable activities. Below is a summary of the key sanctions provisions provided in the legislation.
broad sanctions on Russia’s energy and defense sectors and increase military and nonmilitary assistance to Ukraine.White House officials have indicated that
the President is expected to sign the legislation into law. The legislation includes a mix of mandatory and discretionary sanctions that could significantly
discourage investment in, and transactions with, Russia’s energy and defense sectors. The legislation also authorizes extraterritorial sanctions aimed at
foreign financial institutions that facilitate certain sanctionable activities. Below is a summary of the key sanctions provisions provided in the legislation.