Russia Sanctions:  The U.S., EU, and UK continue to apply pressure on Russia through new sanctions on oligarchs and politicians and restrictions on exports.  A number of other countries have implemented similar measures and continue to widen the scope of such prohibitions as the invasion continues.  On a more limited scale, Belarus has also been subject to new EU restrictions targeting certain financial institutions.  As the invasion continues, we expect additional sanctions and export controls in the near future.

Financial Sector Restrictions: The most recent actions have focused on the Belarusian financial sector.  The EU expanded its prohibition on SWIFT access to three Belarusian banks: Belagroprombank, Bank Dabrabyt, and Development Bank of the Republic of Belarus, which means these banks will be removed from SWIFT effective March 20, 2022.  This action follows the EU’s previous announcement that seven major Russian banks and majority-owned subsidiaries will be disconnected from SWIFT.  The EU also announced that transactions related to the management of reserves or assets of the Central Bank of Belarus are prohibited.

Oligarch Sanctions:  A number of additional oligarchs and prominent businesspeople were sanctioned by the UK and EU this week.   These individuals are involved in key economic sectors that provide a substantial source of revenue to Russia, including the oil, metallurgical, agriculture, pharmaceutical, telecom, and industrial industries.  As the list of sanctioned oligarchs continues to expand, identifying the companies and entities that may also be sanctioned by operation of law, as a result of oligarch ownership or control, will continue to pose a challenge to businesses globally.  We expect the U.S., UK, and EU will continue to target oligarchs as the invasion continues.

Export Controls & Energy Sanctions:  As anticipated, the U.S. announced a ban on the import of Russia origin oil, petroleum, and natural gas.  The Executive Order also prohibits “new investment in the energy sector.”  The definition of “investment” is broad and includes any transaction involving a “contribution of funds or other assets for” new “energy sector activities” that are “located or occurring” in Russia after March 8, 2022.  As a result, this may effectively prohibit the export of any goods for use in the Russian energy sector after March 8, 2022.  The UK announced that it would “phase out” the import of Russian oil over the course of 2022, but offered no specific guidance.

The EU imposed a prohibition on the export of maritime navigation goods and technology to Russia.  This restriction applies to navigation equipment and radio-communication equipment and the provision of technical or financing related to such goods.

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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 Caroline Brown Caroline Brown

Caroline E. Brown is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s White Collar & Regulatory Enforcement and International Trade groups and the steering committee of the firm’s National Security Practice. She provides strategic advice to…

Caroline E. Brown is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s White Collar & Regulatory Enforcement and International Trade groups and the steering committee of the firm’s National Security Practice. She provides strategic advice to clients on national security matters, including anti-money laundering (AML) and economic sanctions compliance and enforcement challenges, investigations, and cross border transactions, including review by the Committee on Foreign Investment in the United States (CFIUS) and the Committee on Foreign Investment in the U.S. Telecommunications Services Sector (Team Telecom).

Caroline brings over a decade of experience as a national security attorney at the U.S. Departments of Justice and the Treasury. At the U.S. Department of Justice’s National Security Division, she worked on counterespionage, cybersecurity, and counterterrorism matters and investigations, and gained unique insight into issues surrounding data privacy and cybersecurity. In that role, she also sat on both CFIUS and Team Telecom and made recommendations to DOJ senior leadership regarding whether to mitigate, block, or allow transactions under review by those interagency committees. She also negotiated, drafted, and reviewed mitigation agreements, monitored companies’ compliance with those agreements, and coordinated and supervised investigations of breaches of those agreements.

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.

Photo of Anand Sithian Anand Sithian

For high-stakes internal and government investigations and complex regulatory and compliance matters, companies and individuals look to Anand to provide strategic advice and counseling, particularly on issues relating to the Bank Secrecy Act and Anti-Money Laundering (“BSA/AML”), economic sanctions, and digital assets. Anand

For high-stakes internal and government investigations and complex regulatory and compliance matters, companies and individuals look to Anand to provide strategic advice and counseling, particularly on issues relating to the Bank Secrecy Act and Anti-Money Laundering (“BSA/AML”), economic sanctions, and digital assets. Anand is resident in the firm’s New York office and a member of the firm’s International Trade, White Collar and Regulatory Enforcement, and Financial Services groups.

A former federal prosecutor, Anand leverages his government experience to guide clients through complex white-collar matters, including grand jury and regulatory investigations, enforcement proceedings, and internal investigations. Anand has deep experience in parallel criminal and civil investigations and proceedings, and often represents clients in defending against civil lawsuits related to government investigations.

Representing some of the world’s largest banks and technology companies, Anand has addressed a wide range of issues, including economic sanctions, BSA/AML; economic sanctions and national security; payments and cryptocurrency; securities laws; and cybersecurity enforcement. In the regulatory space, Anand prides himself on providing commercial and actionable advice, including in the developing areas of digital assets, FinTech, and payments.

Photo of Rachel Schumacher Rachel Schumacher

Rachel Schumacher is an associate in the International Trade and Government Contracts groups in Crowell & Moring’s Washington, D.C. office. Rachel’s practice focuses on transactions, investigations, and compliance and advisory matters involving a variety of government contracts and international trade issues.