New Updates for 11-Jan-2024

2024-01-11

Reading Time : 6 min

The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:

  • 03 Jan 2024 (EU):

    The Akin Summary document has now been posted for this action.

    ​The EU designated one individual and one entity under its Russia sanctions regime for the purposes of an asset freeze and travel ban.

  • 02 Jan 2024 (UK):

    The Akin Summary document has now been posted for this action.

    ​The Office of Financial Sanctions Implementation (“OFSI”) amended General Licence ("GL") INT/2022/1280876 concerning payments to Russian Banks, UK, Guernsey, and EU subsidiaries in respect of basic needs, routine holding and maintenance, legal fees, and insolvency related payments.

  • 22 Dec 2023 (UK):

    The Akin Summary document has now been posted for this action.

    ​The Office of Financial Sanctions Implementation ("OFSI") amended the expiry date of General Licence INT/2022/1710676 in respect of the continuation of business with Evraz Plc's North American subsidiaries.

  • 22 Dec 2023 (OFAC):

    The Akin Summary document has now been posted for this action.

    ​President Biden issued Executive Order ("EO") 14114, pursuant to the national emergency declared in EO 14024, which:

    • Amends EO 14024 by authorizing the imposition of blocking or correspondent account or payable through account ("CAPTA") sanctions on foreign financial institutions that (1) have conducted or facilitated any "significant transaction" for or on behalf of certain persons blocked under EO 14024; or (2) have conducted or facilitated any "significant transaction," or provided any service, involving Russia's military-industrial base, including the direct or indirect provision to Russia of certain items or classes of items identified by the Secretary of the Treasury, in consultation with the Secretaries of State and Commerce.
    • Amends EO 14068 to authorize prohibitions related to the importation into the United States of "Russian origin" fish, seafood, diamonds, and any other products identified by the Secretary of the Treasury in consultation with the Secretaries of State, Commerce, and Homeland Security that have been incorporated or substantially transformed into other products outside of Russia, as well as products containing "Russian origin" fish, seafood, or diamonds (whether independently or after being incorporated/substantially transformed into other products outside of Russia) and any products subject to these new prohibitions that have transited through or were exported from or by the Russian Federation.

    Concurrent with EO 14114, the Office of Foreign Assets Control (“OFAC”): (1) issued a Determination pursuant to EO 14114, specifically identifying the items and classes of items within the scope of EO 14114's prohibition on foreign financial institutions conducting or facilitating any "significant transaction," or providing any service, related to the direct or indirect provision of these items to Russia; and (2) issued a Determination pursuant to EO 14114, identifying salmon, cod, pollock, and crab as the categories of Russian-origin, fish and seafood subject to EO 14114's new prohibitions on the importation of such items into the United States.

  • 22 Dec 2023 (OFAC):

    The Akin Summary document has now been posted for this action.

    ​President Biden issued Executive Order ("EO") 14114, pursuant to the national emergency declared in EO 14024. Concurrent with President Biden's issuance of EO 14114, the Office of Foreign Assets Control ("OFAC"):

    • Issued a Compliance Advisory, providing foreign financial institutions with guidance on the new prohibitions imposed by EO 14114, including guidance on identifying sanctions risks and complying with EO 14114's new prohibitions.
    • Made a technical amendment to its Determination pursuant to EO 14068, which prohibits importation into the United States of Russian-origin gold to reference EO 14114.​​
    • Issued two new Russia-related General Licenses ("GLs") authorizing, subject to certain conditions specified in each general license: (1) certain transactions related to the importation into the United States of Russian-origin fish and seafood prohibited by EO 14068 (GL 83); and (2) certain transactions related to the closing of correspond accounts or payable-through accounts (“CAPTA”) of foreign financial institutions which are the target of CAPTA sanctions authorized under EO 14114 (GL 84).
    • Issued Russia-related GL 85, which authorizes, subject to certain conditions, certain wind down transactions and the closing of accounts involving Expobank Joint Stock Company.
    • Issued 12 new Russia-related Frequently Asked Questions related to EO 14114 and amended three existing Russia-related Frequently Asked Questions.
  • 22 Dec 2023 (EU):

    The Akin Summary document has now been posted for this action.

    ​The EU updated its Russia Sanctions FAQs by clarifying whether the transit of goods listed in Articles 2, 2a, 2aa, 3c and 3k of Council Regulation 833/2014 from the Union through Russian territory to a third country is permitted.

  • 22 Dec 2023 (EU):

    The Akin Summary document has now been posted for this action.

    ​The EU published new Russia Sanctions FAQs to assist EU persons seeking to divest from Russia. The FAQs explain why the derogations contained in Article 12b(1) and (2) of Council Regulation 833/2014 were introduced, and how the sale of shares of a Russian subsidiary which holds goods and technologies listed in Annexes II, VII, X, XI, XVI, XX and XXIII to Council Regulation 833/2014 and Annex I of Regulation (EU) 2021/821 to a Russian buyer should be considered.

  • 22 Dec 2023 (EU):

    The Akin Summary document has now been posted for this action.

    ​The EU updated its Russia Sanctions FAQs by publishing new guidance in respect of the diamond import ban introduced by the EU's 12th sanctions package against Russia. The FAQs provide further clarity regarding the gradual implementation of the import ban, the restrictive measures applicable to diamond jewellery, the traceability-based verification and certification mechanism, as well as the role of the Kimberley Process in connection with Article 3p of Council Regulation 833/2014.

  • 20 Dec 2023 (OFAC):

    The Akin Summary document has now been posted for this action.

    ​OFAC updated its guidance on the implementation of the price cap policy for Russian-origin crude oil and petroleum products. The guidance now, among other things, requires that, in some situations, certain Price Cap Coalition service providers receive attestations within a specified timeframe that are related to the lifting and loading of Russian oil or petroleum products from counterparties and retain, provide, or receive certain ancillary cost information.

  • 20 Dec 2023 (OFAC):

    The Akin Summary document has now been posted for this action.

    OFAC identified one vessel as blocked property ("Blocked Vessel") and designated four entities based in the UAE and Hong Kong under E.O. 14024. OFAC designated the Blocked Vessel's UAE-based owner for being owned by the Government of Russia and designated the remaining three entities for being oil traders who have frequently participated in the seaborne transportation of Russian-origin oil following the price cap policy's implementation. These actions were taken to tighten enforcement of the price cap on Russian-origin oil and petroleum products.

    Concurrent with these actions, OFAC issued two general licenses: (i) General License 81, which authorizes certain safety and environmental transactions with any vessels in which the blocked persons or entities specifically enumerated in the general license has a property interest ("GL 81 Blocked Vessels"), including transactions related to the health or safety of the GL 81 Blocked Vessels' crew, emergency repairs of the GL 81 Blocked Vessels, and environmental mitigation and protection activities relating to the GL 81 Blocked Vessels through 12:01 a.m. Eastern Daylight Time, March 19, 2024, subject to certain conditions; and (ii) General License 82, which authorizes the wind down of transactions involving SUN Ship Management D Ltd and any entity it owns, directly or indirectly, 50% or more through 12:01 a.m. Eastern Daylight Time, March 19, 2024, subject to certain conditions.

  • 20 Dec 2023 (UK):

    The Akin Summary document has now been posted for this action.

    ​The Office of Financial Sanctions Implementation ("OFSI") updated both its UK Maritime Services Ban and Oil Price Cap – Industry Guidance (the "UK Price Cap Guidance") and its UK General Licence INT/2022/2469656 ("GL INT/2022/2469656") with respect to the UK's oil price cap regime. Among the provisions are guidelines on the future attestation model the UK will be introducing from February 19, 2024 onwards, clarification on the reporting obligations of UK nationals in third countries, and updates to the reporting and information recording obligations of in-scope persons.

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