Russia Sanctions:  As the war enters its fifth week, the U.S. and UK continue to expand the restrictions and add to the list of designated individuals and entities.  Relative to sanctions and other prohibitions previously announced, there were few developments over the past week, but additional targeted sanctions may be forthcoming should the Russian invasion intensify.

UK Geographic-Based Restrictions: The UK extended its previous restrictions on Crimea to include “non-government controlled Ukrainian territory,” defined by cross-reference to the territories defined in Ukrainian law as being temporarily occupied, such as  Donetsk and Luhansk.  As a result, the new restrictions prohibit investments, exports, imports, and shipping in those areas.  Many of the restrictions include a wind-down for activity carried out under a contract concluded (or executed) before February 23, 2022, and that is carried out (or completed) before May 24, 2022, (for certain financial services) or August 24, 2022 (for certain trade, infrastructure, and tourism services).

Expansion of U.S. Sanctions Authorities: This week, the U.S. expanded its Russia sanctions authorities to include the aerospace, marine, and electronics sectors of the Russian economy.  This follows previous determinations with respect to the financial services, technology, and defense and related materiel sectors of the economy pursuant to section 1(a)(i) of Executive Order (E.O.) 14024.  The determination permits the future imposition of sanctions on any individual or entity determined to operate or have operated in any of those sectors, but otherwise has no immediate effect.

List of Aircraft Violating U.S. Export Controls: A total of 73 aircraft were added to a list of those flown to Russia in violation of U.S. export controls.  Services related to these aircraft, including within Russia, now must be specifically authorized by the U.S. government.  In particular, refueling, maintenance, repair, or the provision of spare parts or services for the aircraft is otherwise prohibited.  The list of aircraft is not exhaustive, and the restrictions apply automatically to any aircraft that are flown to Russia in violation of U.S. Export Administration Regulations (EAR).

Sanctions Evasion Networks: The U.S. and UK designated for asset freezes entities and individuals involved in evading sanctions to procure sensitive technology and dual-use equipment for Russia.  In a press release, the U.S. described a multi-country network including companies in Russia, the UK, and Spain, which procured key equipment for the Russian government.  The EU and Japan have also previously implemented export restrictions on some of the entities.

Technology Company Sanctions: To further restrict Russia’s access to Western technology, the U.S. imposed blocking sanctions on four Russian technology companies that are involved in software, hardware, and research.

Russian Media Sanctions: In the most recent round of sanctions, the UK targeted Russian media outlets and their leaders.  Rossiya Segodnya and TV-Novosti were designated and are subject to an asset freeze.  Other notable designations include the CEO of Gazprom-Media Holding, managing director of RT, and senior executive of Rossiya Television and Radio network.

UK Restrictions Related to Oligarchs: The UK also passed legislation that prohibits the maintenance of aircraft or ships that belong to sanctioned Russian oligarchs or their businesses.

 

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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.