The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 01 May 2024 (UK):
The Akin Summary document has now been posted for this action.
The Office of Financial Sanctions Implementation ("OFSI") introduced UK Financial Sanctions Frequently Asked Questions ("FAQs"), a new form of additional guidance aimed at providing technical support to industry partners and the public.
- 01 May 2024 (OFAC):
The Akin Summary document has now been posted for this action.
The U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") and the U.S. Department of State concurrently designated over 280 individuals and entities, and identified 16 vessels as blocked property (the "Blocked Vessels"), pursuant to Executive Order ("E.O.") 14024 and E.O. 13382. The designations target Russia's military-industrial base and chemical and biological weapons programs, as well as companies and individuals in third countries, such as Azerbaijan, Belgium, China, Russia, Slovakia, Türkiye, and the United Arab Emirates, that help Russia evade and circumvent sanctions to acquire key inputs for weapons or defense-related production intended to further its war in Ukraine.
Concurrent with these designations, OFAC issued General License ("GL") 95, GL 96, and GL 97, all of which authorize, subject to certain conditions, certain activities involving certain persons and vessels blocked on May 1, 2024.
Concurrent with these designation actions, the U.S. Department of State also delivered to Congress a determination pursuant to the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 regarding Russia's use of the chemical weapon chloropicrin against Ukrainian troops, which re-imposes restrictions on foreign military financing, U.S. Government lines of credit, and certain export licenses for defense articles and national security-sensitive items going to Russia.
- 01 May 2024 (OFAC):
The Akin Summary document has now been posted for this action.
The Department of Justice ("DOJ"), in coordination with the DOJ Task Force KleptoCapture, filed a forfeiture complaint today against a set of aircraft landing gear for a Boeing 737-800 that was detained in September 2023 by U.S. Customs and Border Patrol ("CBP"). The gear was allegedly purchased by an intermediary in Istanbul, GQ Solutions Elektronik Ekipman Limited Sirketi, for the benefit of a Kyrgyz Republic-based transhipper of dual-use items servicing Russia in connection with a previously U.S.-designated entity, LLC RM Design and Development ("RMDD"), in violation of U.S. sanctions. Concurrent with this forfeiture action, the U.S. Department of State announced new sanctions against entities for operating or having operated in the technology sector of the Russian Federation, including GQ Solution Elektronik Ekipman Limited Sirketi in connection with the company's supplying of electronic components to Russia-based companies.
- 30 Apr 2024 (BIS):
The Akin Summary document has now been posted for this action.
The Department of Justice ("DOJ") announced that Nikolay Grigorev pled guilty to conspiracy 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 was charged in November 2022 with conspiracy and related charges alongside two co-defendants, Nikita Arkhipov and Artem Oloviannikov, who still remain at large.
- 29 Apr 2024 (OFAC):
The Akin Summary document has now been posted for this action.
OFAC issued amended General License ("GL") 8I, which authorizes certain transactions related to energy that involve one or more blocked persons that are specifically listed in the GL, extending the authorization until 12:01 a.m. Eastern Daylight Time on November 1, 2024.
- 29 Apr 2024 (UK):
The Akin Summary document has now been posted for this action.
The Office of Financial Sanctions Implementation ("OFSI") renewed General Licence INT/2024/4671884, permitting UK law firms and counsel to provide legal advice to a designated person ("DP") and to receive payment from that person without an OFSI specific license if the terms of the General Licence are met. The new General Licence will expire at 23:59 on October 28, 2024.
- 25 Apr 2024 (BIS):
The Akin Summary document has now been posted for this action.
BIS issued a final rule that amends the Export Administration Regulations ("EAR") to add a new license exception for "medical device"” at § 740.23 (Medical Devices (MED)), which authorizes certain exports, reexports, and transfers (in-country) to or within Russia, Belarus, the temporarily occupied Crimea region of Ukraine, and other covered regions of Ukraine of "medical devices" and related "parts," "components," "accessories," and "attachments" that are designated as EAR99.
- 25 Apr 2024 (UK):
The Akin Summary document has now been posted for this action.
HM Revenue and Customs (HMRC) announced that it had issued a compound settlement of over £1 million to a UK exporter in March 2024. The settlement of £1,058,781.79 relates to the export of goods in breach of The Russia (Sanctions) (EU Exit) Regulations 2019.
- 24 Apr 2024 (OFAC):
The Akin Summary document has now been posted for this action.
President Biden signed into law a wide-ranging legislative package of which Sec. 2 of Division F is the "REPO for Ukrainians Act" ("REPO Act"). This statute provides a mechanism for the eventual transfer of "Russian sovereign assets or any funds or property" for the "purpose of providing assistance to Ukraine for the damage resulting from the unlawful invasion by the Russian Federation that began on February 24, 2022". In the short term, the REPO Act prohibits OFAC from licensing the transfer or release of "funds and other property" that are "effectively immobilized" as a result of the non-blocking Directive 4 Issued Under E.O. 14024, as well as blocked funds of "the Government of the Russian Federation, including by any subdivision, agency, or instrumentality of that government".
- 19 Apr 2024 (OFAC):
The Akin Summary document has now been posted for this action.
OFAC issued General License ("GL") 94, authorizing all transactions prohibited by the Russian Harmful Foreign Activities Sanctions Regulations ("RuHSR") or the Ukraine-/Russia-Related Sanctions Regulations "“URS"”), involving OWH SE i.L. (f.k.a. VTB Bank Europe SE) or any entity in which OWH SE i.L. owns, directly or indirectly, a 50 percent or greater interest ("OWH SE i.L. Entities). GL 94 also unblocks all property and interests in property of OWH SE i.L. Entities.
- 19 Apr 2024 (OFAC):
The Akin Summary document has now been posted for this action.
The U.S. Department of Justice ("DOJ") announced that John Can Unsalan (aka Hurrem Can Unsalan) and his former business associate, Sergey Karpushkin, were sentenced to 6 years and 21 months in prison, respectively, for their roles in a conspiracy to commit money laundering and to violate U.S. sanctions imposed against Sergey Kurchenko and companies owned by Kurchenko.
- 18 Apr 2024 (BIS):
The Akin Summary document has now been posted for this action.
BIS added 39 items to Supplement No. 7 to Part 746 of the Export Administration Regulations ("EAR"), effectively expanding the scope of items that are subject to the EAR under the Russia/Belarus/Temporarily occupied Crimea region of Ukraine Foreign Direct Product ("FDP") rule and the Iran FDP rule.
- 18 Apr 2024 (EU):
The Akin Summary document has now been posted for this action.
The EU published updated FAQs in relation to how sanctions operate in the Donetsk, Kherson, Luhansk, and Zaporizhzhia oblasts, making updates to the guidance on operator assessment and the processing of financial transactions by banks.
- 18 Apr 2024 (EU):
The Akin Summary document has now been posted for this action.
The EU updated the FAQs in relation to the import, purchase, and transfer of listed goods, adding a new FAQ in relation to the newly introduced status of "partner countries for the importation of iron and steel" in Art. 3g(1)(d) of Council Regulation 833/2014 ("EU Regulation").
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