On April 15, 2021, the United States unveiled a sweeping series of additional sanctions on Russia, marking the first major Russia-related sanctions development of the Biden Administration and the most material such U.S. action in several years.  The actions were spearheaded by President Biden’s issuance of an as-yet-unnumbered Executive Order (the “EO”) that grants the Department of Treasury a wide-ranging set of new designation authorities, including to designate persons “operating in” the “technology” and “defense and related material” sectors of the Russian economy.  Acting under this authority, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated six Russian entities for operating in the “technology” sector as well as expanding existing restrictions on U.S. financial institutions to now restrict participation in the primary market for certain ruble-, as well as non-ruble-denominated bonds, as well as certain ruble- or non-ruble-denominated lending activities.

For more on this, as well as parallel actions taken by OFAC, please click here.

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Photo of Dj Wolff Dj Wolff

David (Dj) Wolff is the co-chair of Crowell & Moring’s International Trade Group and a director with Crowell Global Advisors, the firm’s trade policy affiliate.

At Crowell & Moring, he serves on the steering committee for the International Trade Group, where his practice

David (Dj) Wolff is the co-chair of Crowell & Moring’s International Trade Group and a director with Crowell Global Advisors, the firm’s trade policy affiliate.

At Crowell & Moring, he serves on the steering committee for the International Trade Group, where his practice focuses on all aspects of compliance with U.S. economic sanctions, including day-to-day compliance guidance, developing compliance programs, responding to government inquiries, conducting internal investigations, and representation during civil and criminal enforcement proceedings. Dj works regularly with non-U.S. clients, both in Europe and Asia, to evaluate the jurisdictional reach of U.S. sanction authorities to their global operations, identify and manage the potential conflict of laws that can result from that reach, as well as to support client’s design, implementation, and evaluation of a corresponding risk-based sanctions compliance program. Dj also regularly leads teams in diligence efforts on trade and related regulatory areas on behalf of his U.S. and non-U.S. clients in the M&A arena, having successfully closed more than 30 deals with an aggregate valuation of several billion dollars over the last 18 months.

Dj is ranked by Chambers USA in International Trade: Export Controls & Economic Sanctions. He has previously been recognized by Law360 as a Rising Star in International Trade (2020), by The National Law Journal as a “DC Rising Star” (2019), by Who’s Who Legal: Investigations as a “Future Leader” (2018 and 2019), Acritas Star as an Acritas Stars Independently Rated Lawyers (2019), by Global Investigations Review as one of the “40 under 40” in Investigations internationally (2017), and WorldECR as one of the five finalists for the WorldECR Young Practitioner of the Year award (2016).

Photo of Carlton Greene Carlton Greene

Carlton Greene is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade and White Collar & Regulatory Enforcement groups. He provides strategic advice to clients on U.S. economic sanctions, Bank Secrecy Act and anti-money laundering…

Carlton Greene is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade and White Collar & Regulatory Enforcement groups. He provides strategic advice to clients on U.S. economic sanctions, Bank Secrecy Act and anti-money laundering (AML) laws and regulations, export controls, and anti-corruption/anti-bribery laws and regulations. Carlton is the former chief counsel at FinCEN (the Financial Crimes Enforcement Network), the U.S. AML regulator responsible for administering the Bank Secrecy Act.

Robert Clifton Burns

Robert Clifton Burns is a senior counsel in Crowell & Moring’s Washington, D.C. office. Clif focuses his practice on export controls, economic sanctions, customs, national security, and the Foreign Corrupt Practices Act. He represents clients in France, Germany, the Netherlands, Australia, and the

Robert Clifton Burns is a senior counsel in Crowell & Moring’s Washington, D.C. office. Clif focuses his practice on export controls, economic sanctions, customs, national security, and the Foreign Corrupt Practices Act. He represents clients in France, Germany, the Netherlands, Australia, and the United States.

His clients are in a broad range of industries including medical devices, military equipment, financial services, travel and hospitality, and agriculture. Clif counsels clients on compliance matters as well as, in handling internal investigations, voluntary disclosures, and criminal defense. In addition, he represents M&A clients in international transactions with national security implications before the Committee on Foreign Investment in the United States.

Clif’s export control work encompasses a broad range of areas and includes matters involving the Export Administration Regulations administered by the Department of Commerce, the International Traffic in Arms Regulations administered by the State Department, and the country-based economic sanctions program administered by the Office of Foreign Assets Control of the Treasury Department. He also has experience in developing compliance programs for each of these three regulatory schemes, conducting due diligence for compliance with these schemes, and submitting voluntary disclosures of prior unlicensed exports.

Clif was an adjunct professor of law at the Georgetown University Law Center from 2004 until 2016. He was editor-in-chief of the Northwestern University Law Review and a law clerk for the Honorable Robert A. Sprecher with the U.S. Court of Appeals for the Seventh Circuit.

He speaks fluent French.