The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 03 Feb 2023 (OFAC):
On February 3, 2023, OFAC issued a Determination pursuant to Executive Order (EO) 14071 prohibiting the exportation, reexportation, sale, or supply, directly or indirectly, from the United States or by a United States person of any of the following categories of services as they relate to the maritime transport of petroleum products of Russian Federation origin to any person located in the Russian Federation: trading/commodities brokering, financing, shipping, insurance, including reinsurance and protection and indemnity, flagging, and customs brokering (the “Covered Services”), effective 12:01 a.m. EST on February 5, 2023.
OFAC also issued a related Determination pursuant to EO 14071, effective at 12:01 am EST on February 5, 2023, setting the price cap for Russian origin petroleum products (articles defined under HTSUS heading 2710). Specifically, the determination set the price cap for Russian-origin discount-to-crude petroleum products at USD 45 per barrel, and the price cap for Russian-origin premium-to-crude petroleum products at USD 100 per barrel. OFAC also updated its guidance on the implementation of the price cap policy for Russian-origin crude oil and petroleum products; such updated guidance now includes, among other things, a listing of products that qualify as either “premium-to-crude” or “discount-to-crude” petroleum products.
Finally, OFAC issued General Licenses (GL) 56A, authorizing, subject to certain conditions, certain services, related to the import of the covered crude oil and petroleum products, into the Republic of Bulgaria, the Republic of Croatia, or landlocked European Union member states as described in Council Regulation (EU) 2022/879, and GL 57A, authorizing, subject to certain conditions, certain services necessary to address vessel emergencies related to the health or safety of the crew or environmental protection (such GLs were previously issued with respect to Russian-origin crude products, but now have been expanded to cover petroleum products as well).
- 02 Feb 2023 (Canada):
Content provided in collaboration with McCarthy Tétrault.
Canada lists an additional 22 individuals and 16 entities under the Special Economic Measures (Russia) Regulations.
- 01 Feb 2023 (OFAC):
OFAC designated 22 individuals and entities related to a sanctions evasion network led by a Russia- and Cyprus-based arms dealer, Igor Vladimirovich Zimenkov, pursuant to Executive Order 14024. According to OFAC, Zimenkov’s global network supports Russia’s military-industrial complex and certain state-owned sanctioned Russian defense entities. The actions were taken as part of the U.S. Department of the Treasury’s commitment to the Russian Elites, Proxies, and Oligarchs (“REPO") Task Force, a multilateral effort to identify, freeze, and seize assets of sanctioned Russians worldwide.
- 01 Feb 2023 (Australia):
Australia has designated four Iranian individuals and four Iranian entities involved in the supply of drones to Russia for the war with Ukraine.
- 26 Jan 2023 (OFAC):
OFAC designated “Russian proxy” organization PMC Wagner (Wagner Group), a Russian private military company, pursuant to Executive Order (E.O.) 13581, as amended by E.O. 13863, for being a foreign person that constitutes a significant transnational criminal organization and under E.O. 13667, an authority under the Central African Republic Sanctions Regulations. PMC Wagner was already designated under E.O. 14024 for its operations in Russia. OFAC also designated four entities pursuant to E.O. 14024, and three entities and two individuals under E.O. 13667, all of which are alleged to support the Wagner Group’s military operations. OFAC additionally designated eight entities and six individuals, and identified four aircraft as property in which a blocked person has an interest, under E.O. 14024 for supporting Russia’s defense industrial complex or for their affiliation with Vladimir Putin. Finally, the State Department designated 19 entities and 10 individuals, and identified two aircraft and one yacht as property in which a blocked person has an interest under E.O. 14024, in an action targeting the infrastructure that supports Russia’s battlefield operations in Ukraine, as well as Russian government officials and extended networks of designated persons such as Vladimir Potanin and Sergei Adonev. The State Department additionally imposed visa restrictions on 531 members of the Russian military.
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