The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 22 Dec 2023 (UK):
The Office of Financial Sanctions Implementation ("OFSI") amended the expiry date of General Licence INT/2022/1710676 in respect of the continuation of business with Evraz Plc's North American subsidiaries.
- 22 Dec 2023 (OFAC):
President Biden issued Executive Order ("EO") 14114, pursuant to the national emergency declared in EO 14024, which:
- Amends EO 14024 by authorizing the imposition of blocking or correspondent account or payable through account ("CAPTA") sanctions on foreign financial institutions that (1) have conducted or facilitated any "significant transaction" for or on behalf of certain persons blocked under EO 14024; or (2) have conducted or facilitated any "significant transaction," or provided any service, involving Russia's military-industrial base, including the direct or indirect provision to Russia of certain items or classes of items identified by the Secretary of the Treasury, in consultation with the Secretaries of State and Commerce.
- Amends EO 14068 to authorize prohibitions related to the importation into the United States of "Russian origin" fish, seafood, diamonds, and any other products identified by the Secretary of the Treasury in consultation with the Secretaries of State, Commerce, and Homeland Security that have been incorporated or substantially transformed into other products outside of Russia, as well as products containing "Russian origin" fish, seafood, or diamonds (whether independently or after being incorporated/substantially transformed into other products outside of Russia) and any products subject to these new prohibitions that have transited through or were exported from or by the Russian Federation.
Concurrent with EO 14114, the Office of Foreign Assets Control (“OFAC”): (1) issued a Determination pursuant to EO 14114, specifically identifying the items and classes of items within the scope of EO 14114's prohibition on foreign financial institutions conducting or facilitating any "significant transaction," or providing any service, related to the direct or indirect provision of these items to Russia; and (2) issued a Determination pursuant to EO 14114, identifying salmon, cod, pollock, and crab as the categories of Russian-origin, fish and seafood subject to EO 14114's new prohibitions on the importation of such items into the United States.
- Amends EO 14024 by authorizing the imposition of blocking or correspondent account or payable through account ("CAPTA") sanctions on foreign financial institutions that (1) have conducted or facilitated any "significant transaction" for or on behalf of certain persons blocked under EO 14024; or (2) have conducted or facilitated any "significant transaction," or provided any service, involving Russia's military-industrial base, including the direct or indirect provision to Russia of certain items or classes of items identified by the Secretary of the Treasury, in consultation with the Secretaries of State and Commerce.
- 22 Dec 2023 (OFAC):
President Biden issued Executive Order ("EO") 14114, pursuant to the national emergency declared in EO 14024. Concurrent with President Biden's issuance of EO 14114, the Office of Foreign Assets Control ("OFAC"):
- Issued a Compliance Advisory, providing foreign financial institutions with guidance on the new prohibitions imposed by EO 14114, including guidance on identifying sanctions risks and complying with EO 14114's new prohibitions.
- Made a technical amendment to its Determination pursuant to EO 14068, which prohibits importation into the United States of Russian-origin gold to reference EO 14114.
- Issued two new Russia-related General Licenses ("GLs") authorizing, subject to certain conditions specified in each general license: (1) certain transactions related to the importation into the United States of Russian-origin fish and seafood prohibited by EO 14068 (GL 83); and (2) certain transactions related to the closing of correspond accounts or payable-through accounts (“CAPTA”) of foreign financial institutions which are the target of CAPTA sanctions authorized under EO 14114 (GL 84).
- Issued Russia-related GL 85, which authorizes, subject to certain conditions, certain wind down transactions and the closing of accounts involving Expobank Joint Stock Company.
- Issued 12 new Russia-related Frequently Asked Questions related to EO 14114 and amended three existing Russia-related Frequently Asked Questions.
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