The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 14 Apr 2023 (New Zealand):
Content provided in collaboration with Chapman Tripp.
The Russia Sanctions Amendment Regulations (No.4) 2023 came into force. They amend the prohibitions relating to import of luxury goods from Russia.
- 13 Apr 2023 (EU):
The EU has designated the Wagner Group and RIA FAN under its Russia sanctions framework. The Wagner Group is already subject to EU sanctions under the EU Global Human Rights Sanctions Regime.
- 12 Apr 2023 (UK):
On April 12, 2023, the UK Foreign, Commonwealth and Development Office amended one existing entry and added 14 new entries to the Russia sanctions list of designated persons for the purposes of an asset freeze targeting those who knowingly assisted sanctioned Russian oligarchs with concealing their assets to evade sanctions.
- 12 Apr 2023 (OFAC):
OFAC designated 25 individuals and 29 entities pursuant to E.O. 14024 for facilitating Russia’s access to the international financial system and evading U.S. sanctions on Russia, with a significant focus on targeting the facilitation network of the previously designated Alisher Usmanov. These individuals and entities include facilitators of Usmanov’s financial network operating in the Russian Federation and Cyprus, a trust services company and certain individuals associated with it, a Russian procurement and sanctions evasion network, and the Hungarian-based International Investment Bank. Concurrently, the U.S. Department of State designated over 80 individuals and entities linked to Usmanov, operating in the defense sector of the Russian Federation economy, supporting Russia’s war against Ukraine, and for their association with Russia’s State Atomic Energy Corporation (Rosatom), and identified 19 vessels as blocked property. These individuals and entities include members of Usmanov’s network, members of Christodoulos Vassiliades’ network, a lawyer whom the Department of State alleges has enabled prominent Russian businessmen, and Aleksei Bashkirov, a member of the board of directors of Norilsk Nikel, and members of his network. The Department of State additionally designated entities associated with Rosatom, though Rosatom itself remains undesignated. In total, 91 entities, 34 individuals and 19 vessels were added to the SDN List by OFAC and the Department of State.
Concurrent with these actions, OFAC issued four general licenses, authorizing certain transactions with specified entities added to the SDN List, including wind down transactions, transactions related to certain debt and equity, and certain transactions related to telecommunication involving two designated entities. OFAC also issued one FAQ clarifying the relationship of General License 65, which authorizes transactions related to telecommunications and certain internet-based communications involving two designated entities, and General License 25C, which authorizes all transactions ordinarily incident and necessary to the receipt or transmission of telecommunications involving the Russian Federation. OFAC additionally revoked Russia-related General License 15, which authorized transactions with any entity owned 50% or more by Usmanov that was not listed on the SDN List.
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