The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 19 May 2023 (OFAC):
On May 19, 2023, OFAC issued a “determination” pursuant to Section 1(a)(ii) of E.O. 14071 prohibiting, effective June 18, 2023, the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a U.S. person, wherever located, of “architecture services or engineering services” to any person located in the Russian Federation. Concurrent with this determination, OFAC issued one new FAQ, FAQ 1128, and amended two existing FAQs, FAQs 1059 and 1061, clarifying the scope of the new prohibition, including providing definitions of the two identified categories of services.
- 19 May 2023 (OFAC):
On May 19, 2023, OFAC issued a “determination” pursuant to Section 1(a)(i) of E.O. 14024 authorizing the imposition of sanctions on persons determined to operate or to have operated in the architecture, engineering, construction, manufacturing, or transportation sectors of the Russian Federation economy. Concurrent with this determination, OFAC issued two FAQs, 1126 and 1127, clarifying the scope of the new designation authority.
- 19 May 2023 (OFAC):
On May 19, 2023, OFAC and the U.S. Department of State designated 240 individuals and entities and identified 83 vessels and aircraft as blocked property in a coordinated action with the G7 and other international partners aimed at further degrading the Russian Federation’s economy and ability to wage war in Ukraine. In total, OFAC and the U.S. Department of State designated 46 individuals and 194 entities pursuant to E.O. 14024. Additionally, the U.S. Department of State identified 5 vessels and 78 aircraft as blocked property. These sanctioned individuals and entities operate in a variety of industries, including energy, education, technology and electronics, and financial services, among others, and include Russian government officials and authorities in occupied parts of Ukraine. According to OFAC, these individuals and entities have touchpoints in more than 20 countries or jurisdictions worldwide.
Concurrent with these designations, OFAC issued three general licenses authorizing certain transactions with Public Joint Stock Company Polyus (“Polyus”), and certain higher education institutions: General License 66, “Authorizing the Wind Down of Transactions Involving Public Joint Stock Company Polyus”; General License 67, “Authorizing Certain Transactions Related to Debt or Equity of, or Derivative Contracts Involving, Public Joint Stock Company Polyus”; and General License 68, “Authorizing the Wind Down of Transactions Involving Certain Universities and Institutes”.
- 19 May 2023 (OFAC):
On May 19, 2023, OFAC issued Russia-related Directive 4 under E.O. 14024, as amended, which replaces and supersedes the prior-issued version of Directive 4 under E.O. 14024. The only substantive change made in the amended Directive 4 is to impose a new reporting requirement for U.S. persons who are in possession or control of property in which the Central Bank of the Russian Federation, Ministry of Finance of the Russian Federation, or National Wealth Fund of the Russian Federation (the “Directive 4 Entities”) has any direct or indirect interest of any nature whatsoever.
Concurrently, OFAC amended Russia-related General License 13, which authorizes certain administrative transactions prohibited by Directive 4, and reissued it as General License 13E, to extend the expiration date of such general license.
Finally, OFAC amended a number of its FAQs, namely FAQs 998-1002, 1004-1005, and 1118, to reflect the above amendments, as well as to make certain technical changes.
- 19 May 2023 (UK):
On May 19, 2023, the United Kingdom designated 42 individuals and 44 entities connected to the energy, metals, defence, transport and financial under The Russia (Sanctions) (EU Exit) Regulations 2019. Further, the UK has announced plans to legislate later this year to ban imports of Russian diamonds, and end all imports of Russian origin copper, aluminium and nickel, building on existing bans of Russian Iron and steel.
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