The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 19 Dec 2023 (BIS):
The Akin Summary document has now been posted for this action.
Following a 13-count indictment unsealed by the Department of Justice ("DOJ") in March 2023, on December 19, 2023, Cyril Gregory Buyanovsky pleaded guilty to conspiracy to circumvent U.S. export controls. According to the DOJ, Buyanovsky and Douglas Edward Robertson, used KanRus Trading Company, Inc. ("KanRus"), an entity they owned, to send sophisticated, U.S.-origin and controlled avionics equipment from the United States to Russia, and to Russian end users outside of Russia, without proper authorization.
- 19 Dec 2023 (EU):
The Akin Summary document has now been posted for this action.
The Council of the EU, together with the Commission, published its 12th round of sanctions including, inter alia, a total of 140 new designations (56 individuals and 87 entities), stricter obligations in respect of the re-export of critical and sensitive goods to Russia, enhanced reporting requirements under the G7+ oil price cap, stronger anti-circumvention measures that seek to enhance transparency and information sharing, and several products are now the subject of import and export controls (including new trade restrictions in respect of diamonds and diamond-jewellery), set out in Council Regulation (EU) 2023/2873 of 18 December 2023, Council Implementing Regulation (EU) 2023/2875 of 18 December 2023, Council Regulation (EU) 2023/2878 of 18 December 2023, Council Decision (CFSP) 2023/2871 of 18 December 2023, and Council Decision (CFSP) 2023/2874 of 18 December 2023.
In connection with these measures, the Council has introduced exemptions relating to personal items, such as personal hygiene, cars, as well as providing extended wind-down periods for the import of specific steel products.
- 14 Dec 2023 (UK):
The Akin Summary document has now been posted for this action.
The UK's Office of Financial Sanctions Implementation ("OFSI") published UK General Licence INT/2023/4078352 ("GL INT/2023/4078352") in respect of UK credit or financial institutions processing payments from or via a Newly Designated Bank.
- 14 Dec 2023 (UK):
The Akin Summary document has now been posted for this action.
The UK Foreign Commonwealth & Development Office ("FCDO"), together with the Department for Business and Trade, formally announced the implementation of the UK's 7th trade sanctions package, set out in the Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2023 and the UK’s import ban on Russian diamonds, implemented by the Russia (Sanctions) (EU Exit) (Amendment) (No. 5) Regulations 2023.
In connection with these new measures, various General Licences ("GLs"), namely INT/2022/2349952, INT/2022/2300292, INT/2023/3626884, INT/2022/2009156, INT/2022/1834876, INT/2022/1839676, INT/2022/1322576, INT/2023/3024200, INT/2022/1552576, NT/2023/3179120 and INT/2023/3744968, have been updated.
Additionally, the UK has published a notice concerning the designation of a number of Russian banks in connection with Regulation 17A, concerning correspondent banking relationships.
- 13 Dec 2023 (BIS):
The Akin Summary document has now been posted for this action.
On December 13, 2023, BIS renewed its Temporary Denial Orders ("TDOs") on Nordwind Airlines ("Nordwind"), Pobeda Airlines ("Pobeda"), and Siberian Airlines d/b/a S7 Airlines ("Siberian"). These renewals are extended renewals for periods of one year.
- 12 Dec 2023 (OFAC):
The Akin Summary document has now been posted for this action.
OFAC and the U.S. Department of State designated 23 individuals and 250 entities, and identified three vessels as blocked property, each pursuant to Executive Order 14024, in an action aimed at disrupting the networks and channels through which Russia supports its military-industrial base and evades sanctions, targeting Russia’s future energy production and export capacity and also the proliferation of military equipment and munitions from the Democratic People's Republic of Korea to Russia. These sanctioned individuals and entities operate in a variety of industries, including the defense and related materiels, technology, financial services, manufacturing, electronics, aerospace, transportation, metals and mining, and construction sectors of the Russian Federation economy. While many of the individuals and entities designated in this action are based in Russia, OFAC and the Department of State also designated entities based in China, Türkiye, the United Arab Emirates, Hong Kong, Pakistan, South Korea, Switzerland, Singapore, Kyrgyz Republic, Maldives, Cyprus, and Tajikistan.
Concurrent with these designations, OFAC issued two general licenses: (i) General License 79, which authorizes the wind down of transactions involving certain entities blocked on December 12, 2023 through 12:01 a.m. Eastern Daylight Time, March 11, 2024, subject to certain conditions, and (ii) General License 80, which authorizes certain transactions with Highland Gold Mining Limited through 12:01 a.m. Eastern Daylight Time, March 11, 2024, subject to certain conditions.
- 11 Dec 2023 (OFAC):
The Akin Summary document has now been posted for this action.
The Departments of Commerce, Justice, Homeland Security, the Treasury, and State issued a "Quint-Seal Compliance Note – Know Your Cargo: Reinforcing Best Practices to Ensure the Safe and Compliant Transport of Goods in Maritime and Other Forms of Transportation," a joint note highlighting common tactics deployed by malign actors in the maritime and other transportation industries, as well as recent criminal and civil enforcement actions taken in response to alleged violations of U.S. sanctions and export controls related to the illicit shipment of cargo. The Quint-Seal Compliance Note also outlines steps that the maritime and other transportation industries can take to ensure compliance with U.S. sanctions and export controls.
- 11 Dec 2023 (BIS):
The Akin Summary document has now been posted for this action.
The Departments of Commerce, Justice, Homeland Security, the Treasury, and State issued a "Quint-Seal Compliance Note – Know Your Cargo: Reinforcing Best Practices to Ensure the Safe and Compliant Transport of Goods in Maritime and Other Forms of Transportation," a joint note highlighting common tactics deployed by malign actors in the maritime and other transportation industries, as well as recent criminal and civil enforcement actions taken in response to alleged violations of U.S. sanctions and export controls related to the illicit shipment of cargo. The Quint-Seal Compliance Note also outlines steps that the maritime and other transportation industries can take to ensure compliance with U.S. sanctions and export controls.
- 11 Dec 2023 (UK):
The Akin Summary document has now been posted for this action.
The UK Department for Business and Trade, together with the Foreign, Commonwealth & Development Office ("FCDO"), announced the creation of the Office of Trade Sanctions Implementation ("OTSI"), which will become operational in early 2024.
- 11 Dec 2023 (UK):
The Akin Summary document has now been posted for this action.
The UK Department for Business & Trade published General Trade Licence "Russia Sanctions - Iron and steel products and relevant processed iron or steel products - Licence number: GBSAN0001" ("GTL"), which authorizes certain activities in respect of iron and steel products that would otherwise be prohibited under Regulations 46D, 46G, 46H and 46I of Chapter 4C (iron and steel products) or Regulations 46IB to 46IE of Chapter 4CA (iron and steel products processed in a third country) of The Russia (Sanctions) (EU Exit) Regulations 2019.
- 09 Dec 2023 (UK):
The Akin Summary document has now been posted for this action.
The UK's Office of Financial Sanctions Implementation ("OFSI") published General Licence INT/2023/3781228 ("GL INT/2023/3781228") in respect of Permitted Payments to Local Authorities by Designated Persons ("DPs") pursuant to all UK Autonomous Sanctions Regulations listed within Annex I of GL INT/2023/3781228.
- 06 Dec 2023 (BIS):
The Akin Summary document has now been posted for this action.
The Department of Justice ("DOJ") unsealed two separate indictments against Hans Marie De Geetere, a Belgian national, for crimes related to a years-long scheme to unlawfully export sensitive military-grade technology from the U.S. to end users in China and Russia. Concurrent with these indictments, the Bureau of Industry and Security ("BIS") and the Office of Foreign Assets Control ("OFAC") added De Geetere and his companies, Knokke-Heist Support Management Corporation and European Trading Technology BV, to the Entity List and Specially Designated Nationals and Blocked Persons ("SDN") List, respectively, for illegally diverting U.S.-origin electronic components used in missiles, unmanned aerial vehicles, electronic warfare receivers, and military radar on behalf of parties in China and Russia.
- 06 Dec 2023 (UK):
The Akin Summary document has now been posted for this action.
The UK designated 25 individuals and 20 entities pursuant to The Russia (Sanctions) (EU Exit) Regulations 2019 (the "Regulations"). As a result, these individual/entities are subject to asset freeze measures, as well as trust services sanctions under the Regulations. In addition, the UK has also designated one entity pursuant to The Republic of Belarus (Sanctions) (EU Exit) Regulations 2019, which is now subject to asset-freeze measures also.
Further to such action, and to raise awareness of Russia's attempts to circumvent UK sanctions, the National Crime Agency ("NCA"), together with the National Economic Crime Centre ("NEEC"), Joint Money Laundering Intelligence Taskforce ("JMLIT") and Office for Financial Sanctions Implementation ("OFSI"), have published a 'Red Alert' guidance document concerning 'Exporting High Risk Goods', which provides information to UK businesses on common techniques suspected to be in use to evade sanctions on the export of high-risk goods, which Russia is using on the battlefield in Ukraine.
- 05 Dec 2023 (BIS):
The Akin Summary document has now been posted for this action.
BIS added 42 entities under 44 entries to the Entity List. These entities are listed under the destinations of Armenia (3), Belarus (1), Belgium (3), China (1), Cyprus (4), Germany (1), Kazakhstan (1), Netherlands (1), Russia (28), and the United Arab Emirates (1). Two entities are added to the Entity List under two destinations, accounting for the difference in the totals.
- 05 Dec 2023 (OFAC):
The Akin Summary document has now been posted for this action.
OFAC designated eleven entities and seven individuals under E.O. 14038, as well as one individual under E.O. 14024. The action targets Alyaksandr Lukashenka's authoritarian regime through its revenue generators, Lukashenka's so-called personal "wallets," and actors who facilitate Russia's war of aggression in Ukraine, coordinate the movement of children from Ukraine to Belarus, and support Lukashenka's regime.
Concurrent with these designations, OFAC issued Belarus General License 10, which authorizes the wind down of transactions involving Tabak Invest LLC and its subsidiaries until 12:01 a.m. EST on February 2, 2024, subject to certain conditions.
- 05 Dec 2023 (OFAC):
The Akin Summary document has now been posted for this action.
OFAC designated nine entities and five individuals based in Russia, Belgium, Cyprus, Sweden, Hong Kong, and the Netherlands under E.O. 14024. The action targets entities and individuals that comprise a network led by Belgium-based Hans De Geetere that is involved in procuring electronics with military applications for Russian end-users. Concurrent with OFAC's action, the U.S. Department of Justice unsealed two separate indictments against Hans De Geetere, related to his years-long scheme of unlawfully exporting sensitive, military-grade technology from the United States to end users located in Russia and the People's Republic of China ("PRC").
- 04 Dec 2023 (BIS):
The Akin Summary document has now been posted for this action.
BIS renewed its Temporary Denial Order ("TDO") on Belarusian airline Belavia Belarusian Airlines ("Belavia"). This renewal is an extended renewal for a period of one year.
- 01 Dec 2023 (OFAC):
The Akin Summary document has now been posted for this action.
OFAC identified three vessels as blocked property (the "Blocked Vessels") and designated each of their respective owners, two UAE and one Liberian company, under E.O. 14024, for operating or having operated in the marine sector of the Russian Federation economy. According to OFAC, the three vessels carried Russian crude oil at prices above $60 per barrel, following the implementation of the price cap policy in December 2022. The Blocked Vessels used U.S. services when transporting the Russian-origin crude oil. These actions were taken as a part of the U.S. Department of the Treasury's commitment to reducing Russian oil profits and ensuring a reliable supply of crude oil and petroleum products to the global market.
Concurrent with these actions, OFAC issued Russia General License 78, which authorizes the safe docking and anchoring of the Blocked Vessels, the preservation of the health or safety of the Blocked Vessels' crew, emergency repairs of the Blocked Vessels, and environmental mitigation and protection activities relating to any of the Blocked Vessels until 12:01 a.m. Eastern Standard Time, February 29, 2024, subject to certain conditions.
Please send an email to subscriptions@overruled.com, if you would like information on how to subscribe to access additional detail about these and other sanctions- and export controls-related actions. If you are already a paid subscriber, please login to OverRuled for access to exclusive content, analysis, and historic search functionality.