The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 08 Nov 2023 (OFAC):
The Akin Summary document has now been posted for this action.
OFAC issued amended General License ("GL") 76A, which authorizes the wind down of transactions involving certain entities blocked on November 2, 2023 through 12:01 am EST, January 31, 2024, to clarify that the license applies to Public Joint Stock Company Saint Petersburg Exchange. GL 76, as previously issued, listed the name as "Saint Petersburg Stock Exchange". The GL is otherwise unchanged.
- 07 Nov 2023 (BIS):
The Akin Summary document has now been posted for this action.
The Bureau of Industry and Security ("BIS") imposed a temporary denial order ("TDO") suspending the export privileges of seven persons and three companies: Nikolay Goltsev, Salimdzhon Nasriddinov, Kristina Puzyreva, Oleg Zenchenko, Yekaterina Vetoshkina, Pavel Chernikov, Vladimir Bochkarev, SH Brothers Group Inc. ("SH Brothers"), SN Electronics, Inc. ("SN Electronics"), and Suntronic F.Z.E. ("Suntronic"). These parties allegedly were involved in a global procurement scheme to evade U.S. sanctions and export controls by shipping millions of dollars in U.S. technology to Russian entities, including companies affiliated with the Russian military.
- 06 Nov 2023 (BIS):
The Akin Summary document has now been posted for this action.
The Department of Commerce's Bureau of Industry and Security (“BIS”) and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network ("FinCEN") issued a joint notice highlighting a new Suspicious Activity Report ("SAR") key term "FIN-2023-GLOBALEXPORT" for financial institutions to reference when reporting potential efforts by individuals or entities to evade U.S. export controls not related to Russia’s invasion of Ukraine. Financial institutions should continue to use the key term "FIN-2022-RUSSIABIS" when filing SARs related to suspected Russian export control evasion.
- 03 Nov 2023 (OFAC):
The Akin Summary document has now been posted for this action.
OFAC designated Russian national Ekaterina Zhdanova pursuant to E.O. 14024 for operating or having operated in the financial services sector of the Russian Federation economy. According to OFAC, Zhdanova has laundered money on behalf of Russian elites and ransomware actors utilizing virtual currency exchanges, including a Russian cryptocurrency exchange designated by OFAC in 2022, to evade U.S. and international sanctions and aid cybercriminals.
- 02 Nov 2023 (OFAC):
The Akin Summary document has now been posted for this action.
OFAC and the U.S. Department of State designated 192 entities and 37 individuals, each pursuant to E.O. 14024, in an action aimed at disrupting the networks and channels through which Russia supports its military-industrial base and evades sanctions, impeding Russia’s technological growth, and targeting Russia’s financial services and energy and extractives sectors. These sanctioned individuals and entities operate in a variety of industries, including the defense and related materials, financial services, technology, energy, metals and mining, electronics, manufacturing, construction, and transportation sectors of the Russian Federation economy. Most of the individuals and entities designated in this action are based in Russia, however, OFAC and the Department of State also designated entities based in China, Turkey, and the United Arab Emirates.
Concurrent with these designations, OFAC issued four general licenses: (i) General License 13G, which extends the authorization of certain administrative transactions prohibited by Directive 4 under E.O. 14024, until 12:01 am EST January 31, 2024 (as well as adding new authorization for the receipt of tax refunds); (ii) General License 74, which authorizes the wind down and rejection of transactions involving East-West United Bank, until 12:01 am EST January 31, 2024; (iii) General License 75, which authorizes all transactions ordinarily incident and necessary to the divestment or transfer, or the facilitation of the divestment or transfer of debt or equity of, or derivative contracts involving, certain entities blocked on November 2, 2023, as well as all transactions ordinarily incident and necessary to facilitating, clearing, and settling trades involving such debt or equity, until 12:01 am EST January 31, 2024; and (iv) General License 76, which authorizes the wind down of transactions involving certain entities blocked on November 2, 2023, until 12:01 am EST January 31, 2024. Each of these general licenses is subject to certain conditions.
- 02 Nov 2023 (BIS):
The Akin Summary document has now been posted for this action.
BIS added 13 entities to the Entity List in Russia (12) and Uzbekistan (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 by procuring, developing, and proliferating Russian unmanned aerial vehicles (UAVs).
- 01 Nov 2023 (BIS):
The Akin Summary document has now been posted for this action.
The Department of Justice (“DOJ”) announced charges against Nikita Arkhipov, Nikolay Grigorev and Artem Oloviannikov of conspiracy and other charges related to a scheme to evade U.S. sanctions and export controls by shipping U.S. technology to Russian entities affiliated with the Russian military. Grigorev has been arrested but Arkhipov and Oloviannikov remain at large.
- 31 Oct 2023 (BIS):
The Akin Summary document has now been posted for this action.
The U.S. Department of Justice ("DOJ") charged Nikolay Goltsev, Salimdzhon Nasriddinov, and Kristina Puzyreva, all Russian nationals, with conspiracy and other charges related to a scheme to evade U.S. sanctions and export controls by shipping millions of dollars in U.S. technology to Russian entities, including companies affiliated with the Russian military.
- 31 Oct 2023 (EU):
The Akin Summary document has now been posted for this action.
The EU updated its FAQs concerning the Central Bank of Russia.
- 27 Oct 2023 (UK):
The Akin Summary document has now been posted for this action.
The Office of Financial Sanctions Implementation ("OFSI") amended General Licence INT/2022/1875276 ("GL") to include Digital Invest Limited Liability Company, PJSC Megafon and its subsidiary companies as designated persons operating in the Civilian Telecommunications sector.
- 25 Oct 2023 (OFAC):
The Akin Summary document has now been posted for this action.
OFAC issued amended General License (GL) 8H, which authorizes certain transactions related to energy that involve one or more blocked persons that are specifically listed in the GL, extending the authorization under such GL until May 1, 2024.
- 25 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/2023/3744968 ("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.
- 23 Oct 2023 (EU):
The Akin Summary document has now been posted for this action.
The EU updated its Russia Sanctions FAQs in respect of state-owned enterprises.
- 19 Oct 2023 (UK):
The Akin Summary document has now been posted for this action.
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.
- 17 Oct 2023 (UK):
The Akin Summary document has now been posted for this action.
The Department for International Trade and Export Control Joint Unit published technical guidance for exporters in respect of the interception and monitoring prohibitions contained within the UK's sanctions regulations against Russia, Belarus, Myanmar (Burma), Syria and Venezuela. The guidance provides further clarity on the interpretation of 14 specific terms, which cover goods and software that could be used to intercept communications, as well as related services.
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