The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 10 Oct 2023 (UK):
The Office of Financial Sanctions Implementation ("OFSI") amended General Licence INT/2023/3024200 ("GL") in respect of Prior Obligations, which was issued pursuant to Regulation 64 of The Russia (Sanctions) (EU Exit) Regulations 2019 ("Russia Regulations") and Regulation 32 of The Republic of Belarus (Sanctions) (EU Exit) Regulations 2019 ("Belarus Regulations"). The GL permits a UK person who is owed funds or economic resources by a designated person ("DP"), under a contract that was signed before the DP in question was designated, to receive payment, provided that the terms of GL INT/2023/3024200 are met.
- 06 Oct 2023 (BIS):
The Akin Summary document has now been posted for this action.
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):
The Akin Summary document has now been posted for this action.
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.
- 06 Oct 2023 (UK):
The Akin Summary document has now been posted for this action.
The Office of Financial Sanctions Implementation ("OFSI") issued General Licence INT/2023/3626884 under all UK Autonomous Sanctions Regulations (see Annex 1 of the General Licence for the list of relevant Regulations), which allows for UK Designated Persons ("DPs") to make Permitted Payments to Companies House and for Persons acting on behalf of UK DPs to make Permitted Payments to Companies House.
- 02 Oct 2023 (EU):
The Akin Summary document has now been posted for this action.
The EU published new Russia Sanctions FAQs in respect of the export-related restrictions for dual-use goods and advanced technologies.
- 02 Oct 2023 (EU):
The Akin Summary document has now been posted for this action.
The EU published new Russia Sanctions FAQs in respect of iron and steel products processed in third countries incorporating iron and steel inputs from Russia.
- 29 Sep 2023 (UK):
The Akin Summary document has now been posted for this action.
The UK designated ten individuals and one entity pursuant to The Russia (Sanctions) (EU Exit) Regulations 2019. The sanctions measures target Russian officials involved in recent sham elections within the Ukrainian oblasts of Kherson, Zaprorizhzhia, Donetsk, Luhansk and Crimea, all of which sought to legitimize the attempted annexation of Ukrainian territory.
- 29 Sep 2023 (UK):
The Akin Summary document has now been posted for this action.
The Office of Financial Sanctions Implementation ("OFSI") issued General Licence INT/2023/3566356 ("GL") in respect of Correspondent Banking Payments pursuant to Regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019 ("Russia Regulations") and Regulation 32 of the Republic of Belarus (Sanctions) (EU Exit) Regulations 2019 ("Belarus Regulations").
- 29 Sep 2023 (EU):
The Akin Summary document has now been posted for this action.
The Council of the EU published its conclusion that the restrictive measures relating to the prohibition against broadcasting activities in the Union, or directed at the Union, referred to in Article 2f of Regulation 833/2014 and Article 4g of Decision 2014/512/CFSP, should apply to all entities referred to in Annex IV of Regulation (EU) 2023/1214 and point (3) of the Annex to Decision (CFSP) 2023/1217 as of October 1, 2023.
- 29 Sep 2023 (UK):
The Akin Summary document has now been posted for this action.
The UK updated its Russia sanctions statutory guidance to include a licensing ground regarding divestment from Russia in respect of: (i) the transfer of oil refining goods and technology; (ii) brokering and financial services relating to oil refining goods and technology; (iii) energy-related goods; (iv) luxury goods; (v) jet fuel and fuel additives; (vi) making available or transferring G7 dependency and goods; (vii) brokering and financial services related to G7 dependency and goods; (viii) vulnerable goods; and (ix) the provision of technical assistance, brokering or financial services or funds as per Regulations 25, 26, 27 – 29, 40 – 42, 43 – 45, 46B, 46N, 46O – 46Q, 46Y, 46Z - 46Z2, 46Z30 and 45Z31 to 46Z33.
- 28 Sep 2023 (BIS):
The Akin Summary document has now been posted for this action.
BIS issued “best practice guidance” regarding signed export control compliance certification statements to help prevent “high-priority items" from being diverted to Russia.
- 25 Sep 2023 (BIS):
The Akin Summary document has now been posted for this action.
BIS added 28 entities to the Entity List, including entities in China (11), Finland (3), Germany (1), Oman (2), Pakistan (5), Russia (5), and the United Arab Emirates (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, including by procuring U.S.-origin items for use in UAVs in Russia and Iran, to further Chinese military research, to support Yemen-based Houthi forces, to contribute to Pakistan’s nuclear activities, and for support of Russian military and security services. BIS also revised the Entity List to add additional aliases and addresses to two Entity List entries (one in Pakistan and one in China) and removed one Chinese entity from the Military End User List.
- 23 Sep 2023 (BIS):
The Akin Summary document has now been posted for this action.
BIS again renewed three Temporary Denial Orders ("TDOs") for three Russian aviation companies: Azur Air, UTair Aviation JSC, and PJSC Aeroflot. Unlike previous TDO renewals for these airlines, these latest renewals extend the TDO for each airline for a period of one year instead of 180 days.
- 21 Sep 2023 (UK):
The Akin Summary document has now been posted for this action.
On September 21, 2023, OFSI issued General Licence (“GL”) INT/2023/3179120 in respect of all UK Autonomous Sanctions Regulations listed within Annex 1 of the GL. The GL allows UK Designated Persons who own or rent properties in the UK to make utility payments to Water Companies (as defined therein) for water and sewage services. The GL takes effect from September 21, 2023 and expires on September 20, 2025.
- 18 Sep 2023 (BIS):
The Akin Summary document has now been posted for this action.
The U.S. Department of Justice (DOJ) charged Maxim Marchenko, a Russian citizen who has resided in Hong Kong, with conspiring to defraud the United States, smuggling, wire fraud, and money laundering offenses. Marchenko, who has been arrested, allegedly participated in a fraudulent scheme to procure U.S.-made microelectronics with both civil and military applications for end users in Russia.
The OverRuled: China Trade Controls Resource Center has been updated with the following actions:
- 06 Oct 2023 (BIS):
BIS added 49 entities to the Entity List, including 42 under destination of the PRC, for providing support to Russia's military and/or defense industrial base.
Specifically, these entities allegedly supplied Russian consignees connected to the Russian defense sector with U.S.-origin integrated circuits classified under Harmonized Tariff System (HTS)-6 codes 854231, 854232, 854233, and/or 854239 after March 1, 2023. Such items are identified in "Tier 1" of the Common High Priority Items List developed by the U.S. and other international partners and require a license under § 746.5(a)(1)(ii) of the EAR when destined to Russia or Belarus since September 15, 2022.
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