The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 15 Feb 2023 (Switzerland):
Switzerland prohibits certain transactions involving Russian petroleum products purchased above set price caps and adds one entity as an additional sanctions target.
- 23 Dec 2022 (OFAC):
On December 23, 2022, President Biden signed the National Defense Authorization Act (“NDAA”) for Fiscal Year 2023. Section 5590(a) of the NDAA, known as the “Gold Act,” requires the President to submit a report to certain committees of Congress within 90 days after enactment, and periodically as necessary thereafter, identifying non-U.S. persons who knowingly participated in a significant transaction for the sale, supply, or transfer (including transportation) of gold, directly or indirectly, to or from the Russian Federation or the Government of the Russian Federation, including from reserves of the Central Bank of the Russian Federation, or that otherwise involve gold in which the Government of the Russian Federation had any interest. Subsequent to the issuance of this report, the Secretary of the Treasury is required to impose asset blocking sanctions on persons named within the report, and also may impose visa restrictions on any persons in the report that are natural persons (in both cases, subject to a national security waiver that may be exercised).
The NDAA also contained a number of sections that mandated new reports from the Executive Branch to Congress. Specifically, Section 5706 requires the Secretary of the Treasury to provide an annual report to Congress on certain specific licenses that have been issued by the Department of the Treasury to U.S. financial institutions over the preceding year that allow such financial institution to provide financial services to the government of a State Sponsor of Terrorism, or persons sanctioned under certain Russian and non-Russian related corruption and human rights abuse legal authorities. In addition, Sections 6807 and 6808 require the Director of National Intelligence to submit reports to Congress with an assessment of the effects of sanctions imposed by the U.S., EU, and other countries in response to the war in Ukraine and the impact of Russia’s invasion of Ukraine on food security, respectively.
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