The OverRuled: BIS Export Controls Module has been updated with the following actions:
- 08 Nov 2023 - Rossiya Airlines - Denial Order; No monetary penalty
On November 8, 2023, BIS renewed the Temporary Denial Order (TDO) issued against Rossiya Airlines (“Respondent”) on May 20, 2022 for a period of one year in relation to the information that indicates that the Respondent was involved in exporting or reexporting 9A991 aircraft, among many others, on flights into Russia after March 2, 2022, without the required BIS authorization. The continued operation of these aircraft by the Respondent, even on domestic routes within Russia and the company’s on-going need to acquire replacement parts and components, many of which are U.S.-origin, presents a high likelihood of imminent violations warranting imposition of a TDO. BIS further found that such apparent violations have been significant and deliberate. Therefore, the renewal of the TDO is necessary in the public interest to prevent imminent violation of the Regulations and to give notice to companies and individuals in the United States and abroad that they should avoid dealing with the Respondent, in connection with export and reexport transactions involving items subject to the Regulations and in connection with any other activity subject to the Regulations. BIS did not impose any monetary penalty.
The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 08 Nov 2023 (UK):
The UK designated 20 individuals and 9 entities pursuant to The Russia (Sanctions) (EU Exit) Regulations 2019 for the purposes of an asset freeze and trust services sanctions.
- 25 Oct 2023 (UK):
The Office of Financial Sanctions Implementation ("OFSI") issued General Licence INT/2023/3744968 ("GL") in respect of legal services pursuant to the Russian (Sanctions) (EU Exit) Regulations 2019 and the Republic of Belarus (Sanctions) (EU Exit) Regulations 2019. The GL permits a UK Law Firm or UK Counsel to provide legal advice to a designated person ("DP") under either the Russia or Belarus regime and to receive payment from that DP without obtaining a specific license from OFSI, provided that the terms of the GL are met.
- 19 Oct 2023 (UK):
The Office of Financial Sanctions Implementation ("OFSI") made several amendments to General Licence INT/2023/3626884 ("GL") in respect of Permitted Payments made by UK designated persons ("DPs"), or Persons acting on behalf of UK DPs, to Companies House.
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