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.

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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.

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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 C&M International, the firm’s trade policy affiliate.

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

…

David (Dj) Wolff is the co-chair of Crowell & Moring’s International Trade Group and a director with C&M International, 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).

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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.

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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.

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