Russia Sanctions:  There were limited developments this week.  There has been speculation that the EU would release its sixth round of sanctions against Russia, but no updates have been reported thus far.  The new package of sanctions is still expected soon.  The U.S. and UK also did not expand their list of designations this week.  However, the UK published amendments for nearly 200 previously-designated individuals that remain subject to an asset freeze.  The amendments were limited to revising reported dates of birth, addresses, and additional information regarding the basis of the designation.

General Licenses and Clarifications:  The UK published a general license that allows transactions with Sberbank CIB (UK) Ltd, or any entity it owns or controls in the UK for the UK subsidiary, to make payments for (i) basic needs, fees; (ii) service charges from holding and maintenance of funds; and (iii) the provision of legal services.

The UK issued separate a general license that permits officers of (i) the Financial Conduct Authority and (ii) any other organization authorized by Her Majesty’s Treasury to carry out any action necessary to comply with a UK court order, a forfeiture notice, or external orders.  The general license also permits activities for asset recovery purposes.

This week, European Commission President Ursula von der Leyen clarified during a press conference that paying for Russian gas in rubles is a breach of EU sanctions.  “To pay in rubles – if this is not foreseen in the contract – is a breach of our sanctions…Companies with such contracts should not accede to the Russian demands.  This would be a breach of the sanctions, so a high risk for the companies.”  This statement came after Russia suspended gas deliveries to Poland and Bulgaria after they refused to pay with rubles.

EU Proposal to Suspend All Duties on Imports from Ukraine

The EU announced a proposal to suspend import duties on all Ukrainian goods for one year.  This would also apply to all anti-dumping and safeguard measures on Ukrainian steel.  The proposal must still be approved by the European Parliament and the Council of the European Union.

 

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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 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.