The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 06 Oct 2023 (BIS):
BIS added 49 entities under 52 entries to the Entity List, including entries under China (42), Estonia (1), Finland (1), Germany (1), India (3), Turkey (2), United Arab Emirates (1), and the United Kingdom (1) for allegedly violating or conspiring to violate U.S. export controls by acting contrary to the national security and foreign policy interests of the United States by providing support to Russia’s military and/or industrial base, specifically by supplying Russian consignees connected to the Russian defense sector with restricted U.S.-origin integrated circuits after March 1, 2023. These entities did not receive a footnote 3 designation.
- 06 Oct 2023 (BIS):
BIS again renewed its Temporary Denial Orders ("TDOs") for two Russian aviation companies: URAL Airlines JSC ("URAL") and Aviastar - TU ("Aviastar"). The renewal for URAL is an extended renewal for a period of one year, but the renewal for Aviastar is only for a period of 180 days.
- 14 Sep 2023 (OFAC):
The Akin Summary document has now been posted for this action.
OFAC and the Department of State designated more than 140 entities and 24 individuals, and identified 2 vessels as blocked property, all pursuant to Executive Order 14024. The sanctions target persons that have allegedly benefitted from, supported, or sustained Russia's war in Ukraine, including prominent Russian business persons, as well as Russia's industrial base, financial institutions, and technology suppliers (including certain Finnish, Turkish, and UAE companies that have contributed to these Russian sectors). In connection with this action, OFAC issued Russia General License (GL) 72, which authorizes the wind down of transactions involving certain entities that were designated on September 14, 2023 until December 13, 2023, subject to certain limitations.
- 14 Sep 2023 (OFAC):
The Akin Summary document has now been posted for this action.
OFAC issued amended General License (GL) 55A, which authorizes certain services related to the maritime transport of crude oil originating from the Sakhalin-2 project, extending the authorization under such GL until June 28, 2024.
- 14 Sep 2023 (UK):
The Akin Summary document has now been posted for this action.
The Office of Financial Sanctions Implementation ("OFSI") amended the General Licence on projects and countries exempted from the Oil Price Cap to extend the expiration date in respect of the Sakhalin-2 Project to June 28, 2024.
- 14 Sep 2023 (EU):
The Akin Summary document has now been posted for this action.
The EU removed 4 individuals and amended the entries for 140 individuals and 41 entities listed under EU asset freeze sanctions against Russia.
- 14 Sep 2023 (BIS):
The Akin Summary document has now been posted for this action.
In conjunction with the United Kingdom and European Union, BIS identified and issued a list of 45 "common high-priority items" that Russia seeks to procure for its weapons programs and which pose a heightened risk of being illegally diverted to Russia or Belarus. The UK and EU also issued updated "high-priority" lists identifying these same 45 items.
- 12 Sep 2023 (EU):
The Akin Summary document has now been posted for this action.
The EU Commission updated its FAQs by amending FAQ 13 in respect of the prohibition against Russian nationals temporarily importing into personal goods and vehicles listed in Annex XXI, and subject to the prohibition in Article 3i of Council Regulation 833/2014, into the Union.
- 08 Sep 2023 (BIS):
The Akin Summary document has now been posted for this action.
The Treasury Department's Financial Crimes Enforcement Network (FinCEN) issued a Financial Trend Analysis (FTA) that indicates suspected evasion by U.S. and non-U.S. parties of U.S. export control restrictions on Russia.
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