Russia Sanctions:  The UK and EU each made over 200 additional designations.  The EU designated several banks that the US previously had sanctioned, including Bank Otkritie, Novicombank, Sovcombank, and VTB Bank.  Both the EU and the UK designated several oligarchs including Alexander Petaykin (associated with Trans Stroy), Evgeny Zubitskiy (Industrial Metallurgical Holding), Grigory Berezkin (ESN Group), and Said Kerimov (Polyus Gold), along with over 100 members of the People’s Council of the so-called Luhansk People’s Republic and of the People’s Council of the so-called Donetsk People’s Republic.  The EU and UK also amended several previously-made designations.

Export & Import Controls:  The UK, U.S., and EU all announced new export or import controls.  The UK prohibited the import, acquisition, supply, and delivery of certain iron and steel products from Russia.  It also prohibited the export of oil refining goods and technology, quantum computing and advanced materials goods and technology, and certain luxury items to Russia.

The U.S. expanded its export license requirements for Russia and Belarus to cover all items on the Commerce Control List (“CCL”).  Previously the restriction only applied to categories 3-9 of the CCL.  Correspondingly, the U.S. updated the Russia/Belarus foreign direct product rule to apply to all items on the CCL.

The EU also introduced restrictions on the import of certain seafoods, chemicals, woods, cement, glass, silver, aluminum, coal, and other solid fossil fuels from Russia.  It further prohibited the export to Russia of a swath of products identified as contributing to “the enhancement of Russian industrial capacities,” and extended its prohibition on the export of banknotes to Russia to also include export to Belarus.  Finally, the EU prohibited road transportation businesses (i.e. freight companies) established in Russia or Belarus from transporting goods by road within the EU.

Financial & Business Restrictions:  EU persons are now prohibited to register, provide an office or address to, or to provide management services to, a trust or similar legal arrangement having as trustor or beneficiary Russian nationals, persons residing in Russia, legal persons present in or organized under the laws of Russia, or persons 50 percent or more owned by such persons.  The EU also prohibited access to a variety of public procurement and public financing mechanisms for any Russian national, or a legal entity or person established in Russia.  Additionally, the EU prohibited providing crypto-asset wallet, account, or custody services to Russian nationals, or legal persons in Russia, if the value is greater than 10,000 EUR.

Aviation & Maritime:  The U.S. revised License Exception Aircraft, Vessels and Spacecraft (AVS) to limit its availability for certain Belarus-related aircraft, and added 10 additional planes to its list of restricted aircraft, including planes owned by Aeroflot, Utair and Belavia.  The EU prohibited providing access to EU ports to any vessels registered under a Russian flag.

 

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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 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 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 Anand Sithian Anand Sithian

Anand Sithian is a counsel in Crowell & Moring’s New York office. He is a member of the International Trade and the White Collar & Regulatory Enforcement groups. Anand advises clients on a variety of regulatory issues and investigations relating to anti-money laundering…

Anand Sithian is a counsel in Crowell & Moring’s New York office. He is a member of the International Trade and the White Collar & Regulatory Enforcement groups. Anand advises clients on a variety of regulatory issues and investigations relating to anti-money laundering (AML), the Bank Secrecy Act (BSA), U.S. economic sanctions, including those administered by the Office of Foreign Assets Control (OFAC), and asset forfeiture matters. Anand routinely counsels clients on the novel application of these laws and regulations to issues involving financial institutions, technology and social media, virtual currency and digital assets (including the seizure and forfeiture of virtual currencies), and the evolving cannabis industry.

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.