Russia Sanctions:  The U.S., UK, and EU continue to apply pressure on Russia through the implementation of additional sanctions.  The U.S. designated dozens of additional individuals and entities under E.O. 14024, including Russian oligarch Konstantin Malofeyev – who had been previously designated by OFAC in 2014 under E.O. 13660 – and more than 40 individuals and entities associated with him.  The U.S. also designated Transkapitalbank (TBK) and its subsidiary Joint Stock Company Investtradebank.  The UK made 26 additional designations.  These designations included several Generals in the Russian military.  Finally, the EU designated two prominent businessmen, Serhiy Vitaliyovich Kurchenko and Yevgeniy Viktorovich Prigozhin.

General Licenses and Clarifications:  The U.S. and UK issued a handful of general licenses and provided additional clarifications regarding the applicability of their respective sanctions.  The U.S. issued a general license authorizing a range of activities by nongovernmental organizations, including of humanitarian, democracy building, education, non-commercial development, and environmental or natural resource protection activities in Ukraine or the Russian Federation.  The U.S. also issued a general license related to the recently designated TBK (and entities owned more than 50 percent by TBK), granting a one-month wind-down period, until May 20, 2022, and another general license allowing certain transactions destined for or originating from Afghanistan in support of efforts to address the humanitarian crisis to continue for six months, until October 20, 2022.  Finally, the U.S. issued guidance through an OFAC FAQ clarifying that U.S. operators of credit card systems are prohibited from processing transactions involving certain sanctioned foreign financial institutions, and that non-U.S. operators of credit systems whose payment cards are issued by sanctioned foreign financial institutions may violate U.S. sanctions if they permit those cards to be used in the U.S.  The UK also issued a general license authorizing certain energy-related payments to be made to Gazprombank. 

Export Enforcement:  The U.S. took enforcement action against a Russian cargo airline, Aviastar, for operating in violation of U.S. export controls.  The U.S. issued a Temporary Denial Order which bans Aviastar from participating in any transactions subject to the EAR, including a ban on exports from the United States and reexports of items subject to the EAR from abroad.Maritime:  President Biden issued a declaration prohibiting Russian-affiliated vessels from entering into U.S. ports.  The banned vessels include Russian flagged vessels, Russian owned vessels, and Russian operated vessels.  The restriction will come into effect on April 28, 2022