The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 23 Aug 2023 (Russia - Countermeasures):
'Unfriendly' shareholders of Russian companies will be able to receive dividends in the amounts not exceeding their investments into Russia carried out after April 1, 2023.
- 18 Aug 2023 (Russia - Countermeasures):
A total of 54 UK citizens are added to the Russian list of "personally sanctioned" individuals.
- 16 Aug 2023 (OFAC):
The Akin Summary document has now been posted for this action.
On August 16, 2023, OFAC designated three entities tied to a sanctions evasion network attempting to support arms deals between Russia and the Democratic People's Republic of Korea ("DPRK"), each of which is affiliated with a Slovakian national whom OFAC designated on March 30, 2023, under DPRK-related E.O. 13551. Specifically, OFAC designated Limited Liability Company Verus, Defense Engineering Limited Liability Partnership, and Versor S.R.O. pursuant to E.O. 13551, for being owned or controlled by, or having acted or purported to act on behalf of, directly or indirectly, Ashot Mkrtychev ("Mkrtychev"), who is individual blocked pursuant to E.O. 13551. According to OFAC, Mkrtychev attempted to facilitate arms deals between Russia and the DPRK, using the three now-blocked entities, including potential plans to transfer over two dozen kinds of weapons and munitions to Russia in exchange for commercial aircraft, raw materials and commodities. Mkrytchev reportedly conducted negotiations with DPRK and Russian officials in an attempt to broker the arms deal.
- 11 Aug 2023 (OFAC):
The Akin Summary document has now been posted for this action.
On August 11, 2023, OFAC designated four individuals and one entity under E.O. 14024. The action targets prominent Russian businesspersons, including Petr Olegovich Aven, Mikhail Maratovich Fridman, German Borisovich Khan, and Alexey Viktorovich Kuzmichev, all of whom serve on the supervisory board of the Alfa Group Consortium; such individuals had already been sanctioned in a number of other jurisdictions including the EU, UK, Australia, Canada, and New Zealand. OFAC also designated a Russian business association that has reportedly been involved in Russia's responses to sanctions imposed by the U.S. and its allies.
OFAC also issued a frequently asked question concurrently, FAQ 1131, which makes clear that LetterOne Holdings S.A. is not blocked, as such entity is not owned 50 percent or more by blocked persons, according to information available to OFAC.
- 11 Aug 2023 (UK):
The Akin Summary document has now been posted for this action.
The UK Secretary of State has issued a General Trade Licence (“GTL”) effective from August 11, 2023, and has published guidance in respect of the prohibition against the provision of Legal Advisory Services ("LAS") under Regulation 54D of The Russia (Sanctions) (EU Exit) Regulations 2019. The GTL addresses concerns raised by The Law Society and lobbying groups that the drafting of the LAS restriction prevented UK persons from providing compliance advice in respect of proposed activities prohibited under sanctions regimes implemented by other jurisdictions.
- 10 Aug 2023 (OFAC):
The Akin Summary document has now been posted for this action.
OFAC amended Russia-related General License 13, which authorizes certain administrative transactions prohibited by Directive 4, and reissued it as General License 13F, to extend the expiration date of such general license.
- 09 Aug 2023 (OFAC):
The Akin Summary document has now been posted for this action.
On August 9, 2023, OFAC designated eight individuals and five entities, and identified one aircraft as blocked property, under E.O. 14038 on the third anniversary of the Belarusian authorities' falsification of the August 2020 presidential election, and the regime's subsequent violent state response to protesting civilians. The designations target revenue generating Belarusian state-owned entities; family members of a close associate of U.S.-designated President of Belarus, Alyaksandr Lukashenka; and persons involved in the repression of Belarusian civil society and Russia's war in Ukraine. The U.S. Department of State is additionally imposing visa restrictions on 101 regime officials and their affiliates for undermining or harming democratic institutions in Belarus under Presidential Proclamation 8015.
Concurrent with these designations, OFAC issued two general licenses: (i) Belarus General License 8, which authorizes the wind down of transactions involving Joint Stock Company Byelorussian Steel Works Management Company of Holding Byelorussian Metallurgical Company (BSW) and its subsidiaries (including Bel-Kap-Steel LLC) until October 9, 2023, subject to certain conditions, and (ii) Belarus General License 9, which authorizes transactions related to civil aviation safety or the wind down of transactions involving Open Joint Stock Company Belavia Belarusian Airlines and its subsidiaries, in each case until September 8, 2023, subject to certain conditions.
- 08 Aug 2023 (UK):
The Akin Summary document has now been posted for this action.
On August 8, 2023, the UK designated 10 individuals and 9 entities under its Russia sanctions regime and 6 entities under its Belarus sanctions regime for contributing to Russia's defense sector and financial sector. This includes individuals and entities in Turkey, Dubai, Slovakia, and Switzerland who are supporting Russia's military, as well as Iranian and Belarusian support.
- 04 Aug 2023 (UK):
The Akin Summary document has now been posted for this action.
On August 4, 2023, the Office of Financial Sanctions Implementation "OFSI") updated the Oil Price Cap and Maritime Services Ban Reporting Forms.
- 03 Aug 2023 (EU):
The Akin Summary document has now been posted for this action.
On August 3, 2023, the EU designated 38 individuals and 3 entities under its Belarus sanctions regime.
- 03 Aug 2023 (EU):
The Akin Summary document has now been posted for this action.
On August 3, 2023, the EU adopted new sanctions against Belarus.
- 02 Aug 2023 (EU):
The Akin Summary document has now been posted for this action.
On August 2, 2023, the EU updated its FAQs concerning the Oil Price Cap.
- 02 Aug 2023 (EU):
The Akin Summary document has now been posted for this action.
On August 2, 2023, the EU updated its FAQs concerning Oil Imports.
- 01 Aug 2023 (UK):
The Akin Summary document has now been posted for this action.
On August 1, 2023, the Office of Financial Sanctions Implementation ("OFSI") issued General Licence INT/2023/3263556, which permits certain dealings with GTLK entities pursuant to their insolvency proceedings.
- 31 Jul 2023 (UK):
The Akin Summary document has now been posted for this action.
On July 31, 2023, the United Kingdom designated six individuals pursuant to The Russia (Sanctions) (EU Exit) Regulations 2019. The sanctions measures target those providing support for "fake news" policy that is destabilizing Ukraine and undermining its territorial integrity and sovereignty.
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