The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 23 Feb 2024 (BIS):
In conjunction with the United Kingdom and European Union, BIS added five HTS codes to the previously issued list of "common high-priority items" that Russia seeks to procure for its weapons programs. BIS added a Tier 4.B, related to Computer Numerically Controlled machine tools and components; the updated list now includes 50 items.
- 23 Feb 2024 (BIS):
BIS added 93 entities under 95 entries to the Entity List under the destinations China (8), India (1), Kyrgyzstan (2), Russia (63), South Korea (1), Turkey (16), and the United Arab Emirates (4). Two entities are added to the Entity List under two destinations, accounting for the difference in the totals.
- 23 Feb 2024 (OFAC):
OFAC and the U.S. Department of State designated over 500 entities and individuals, and identified 12 vessels as blocked property, pursuant to Executive Order (“E.O.”) 14024, as well as one entity pursuant to E.O. 13224. In particular, the action targets Russia's financial infrastructure and military-industrial base, third-country sanctions evaders in Europe, Asia, and the Middle East, and those involved in supporting Russian future energy revenue sources, maintaining Russia's capacity to wage its war in Ukraine, facilitating sanctions evasion and circumvention, and transferring, deporting, and confining Ukraine's children.
Concurrent with these designations, OFAC issued four general licenses: (i) General License (“GL”) 88A, which authorizes the wind down of transactions involving certain entities blocked on February 23, 2024 through 12:01 a.m. Eastern Daylight Time (“EDT”), April 8, 2024, subject to certain conditions; (ii) GL 89, which authorizes the wind down of transactions involving certain financial institutions blocked on February 23, 2024 through 12:01 a.m. EDT, April 8, 2024, subject to certain conditions; (iii) GL 90, 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 February 23, 2024, as well as all transactions ordinarily incident and necessary to facilitating, clearing, and settling trades involving such debt or equity, until 12:01 a.m. EDT, April 8, 2024, subject to certain conditions; and (iv) GL 91A, which authorizes, with respect to certain designated entities, transactions related to the safe docking and anchoring of any vessels in which the specific designated entities have a property interest (“GL Blocked Vessels”), the preservation of the health or safety of the GL Blocked Vessels’ crew, emergency repairs of the GL Blocked Vessels, and environmental mitigation and protection activities relating to any of the GL Blocked Vessels, until 12:01 a.m. EDT, May 23, 2024, subject to certain conditions.
- 23 Feb 2024 (OFAC):
OFAC issued three new FAQs, FAQs 1164, 1165, and 1166, clarifying the scope of the determinations issued by OFAC on February 8, 2024 related to the importation and entry into the United States of diamond jewelry and unsorted diamonds, as well as certain categories of non-industrial diamonds.
OFAC also amended eight FAQs, FAQs 886, 887, 1019, 1022, 1025, 1027, 1092, and 1154, clarifying the scope of Executive Orders (“E.O.”) 14068 and 14024, as amended by E.O. 14114 of December 22, 2023, in relation to foreign financial institutions and certain categories of products, including diamonds and seafood.
- 23 Feb 2024 (OFAC):
The U.S. Departments of State, Labor, Commerce, and the Treasury jointly issued a Russia Business Advisory that highlights risks and considerations for doing business in Russia and Russia-occupied territories of Ukraine, including considerations relating to U.S. sanctions, export controls, and import prohibitions, and risks associated with the proliferation and implementation of repressive laws in Russia and Russia-occupied territories of Ukraine. The Advisory emphasizes the importance of due diligence to ensure compliance with applicable laws and regulations and outlines due diligence recommendations for businesses and individuals.
- 23 Feb 2024 (OFAC):
OFAC designated Joint Stock Company Sovcomflot ("Sovcomflot"), Russia's state-owned shipping company and fleet operator, and identified 14 crude oil tankers as property in which Sovcomflot has an interest. Sovcomflot has also previously been sanctioned by Australia, Canada, New Zealand, and the United Kingdom, and is under certain European Union sanctions restrictions.
Concurrent with these designations, OFAC issued four general licenses: (i) General License (“GL”) 88A, which amends GL 88 and authorizes the wind down of transactions involving certain entities blocked on February 23, 2024 through 12:01 a.m. Eastern Daylight Time ("EDT"), April 8, 2024, subject to certain conditions to include Sovcomflot; (ii) GL 91A, which authorizes, with respect to certain designated entities, transactions related to the safe docking and anchoring of any vessels in which the specific designated entities have a property interest ("GL Blocked Vessels"), the preservation of the health or safety of the GL Blocked Vessels' crew, emergency repairs of the GL Blocked Vessels, and environmental mitigation and protection activities relating to any of the GL Blocked Vessels, until 12:01 a.m. EDT, May 23, 2024, subject to certain conditions, to include Sovcomflot; (iii) GL 92, which authorizes all transactions that are ordinarily incident and necessary to the delivery and offloading of cargo from any vessel identified as blocked property solely due to a property interest of Sovcomflot, or any entity in which Sovcomflot owns, directly or indirectly, a 50 percent or greater interest (“Sovcomflot Vessels”), until 12:01 a.m. EDT, April 8, 2024, provided that the cargo was loaded prior to February 23, 2024, subject to certain conditions; and (ii) GL 93, which authorizes transactions involving Sovcomflot Vessels, subject to certain conditions.
- 22 Feb 2024 (OFAC):
The U.S. Department of Justice's ("DOJ") Task Force KleptoCapture announced additional charges for potential violations of U.S. sanctions, two arrests, and a guilty plea in a "significant" money laundering case. The DOJ is also seeking the forfeiture of $2.5 million in luxury properties.
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