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 a partner and attorney at law in the firm’s Washington, D.C. and London offices and a director with C&M International, the firm’s trade policy affiliate.

At Crowell & Moring, he practices in the International Trade Group, where his practice…

David (Dj) Wolff is a partner and attorney at law in the firm’s Washington, D.C. and London offices and a director with C&M International, the firm’s trade policy affiliate.

At Crowell & Moring, he practices in the International Trade Group, where his practice covers compliance with U.S. economic sanctions, export controls and antiboycott regimes, and anti-money laundering (AML) laws and regulations. He is experienced in providing day-to-day compliance guidance, developing compliance programs including through on-site compliance trainings, responding to government inquiries, conducting internal investigations, representing them during civil and criminal enforcement proceedings, and, in collaboration with colleagues, managing the potential conflict of laws that can arise from the interaction between extraterritorial impacts of U.S. regulations and third country “blocking” laws or data privacy regulations. Dj splits his time between Washington and London, working regularly with European clients and colleagues to provide coordinated guidance on U.S., U.K., and EU sanctions compliance and enforcement. Dj also has extensive experience in international mergers and acquisitions, advising both buyers and sellers regarding the international trade implications of a potential deal.

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.

Photo of Nicole Succar Nicole Succar

Nicole Sayegh Succar is a counsel in Crowell & Moring’s New York office. She is a member of the firm’s International Trade Group and works closely with White Collar & Regulatory Enforcement Group. Nicole provides compliance counseling and investigations services related to U.S.

Nicole Sayegh Succar is a counsel in Crowell & Moring’s New York office. She is a member of the firm’s International Trade Group and works closely with White Collar & Regulatory Enforcement Group. Nicole provides compliance counseling and investigations services related to U.S. economic sanctions, and the Bank Secrecy Act (BSA), and anti-money laundering laws (AML) and regulations. Nicole is a former sanctions officer with the Office of Foreign Assets Control (OFAC), the U.S. Treasury Department agency responsible for administering and enforcing economic sanctions. While at OFAC, Nicole handled complex matters relating to U.S. sanctions against Russia, Iran, North Korea, Cuba, and Syria.