Russia Sanctions:  This week the UK designated 12 individuals and three Russian airlines, JSC Rossiya Airlines, JSC Ural Airlines, and PJSC Aeroflot.  The individuals include: (i) the chair of the board of directors of Russia’s National Media Group; (ii) a member of the board of directors of JSC SOGAZ (an EU- and UK-designated entity); (iii) a general director of Gelendzhik Seaport LLC; (iv) the president of Gazfond; and (v) Vladimir Putin’s ex-wife and relatives, among others.

The sixth round of EU sanctions is subject to negotiations over the proposed oil embargo, and has not been announced.

UK General Licenses:  The UK published a general license that permits transactions with Amsterdam Trade Bank NV (“ATB”), a majority-owned subsidiary of Alfa-Bank JSC, for: (i) basic needs; (ii) payments related to insolvency proceedings; and (iii) winding down transactions with ATB or any entity it owns or controls.  ATB filed for bankruptcy in the Netherlands on April 22, 2022.

The UK also extended the wind-down license for Sovcomflot, which is now set to expire at the end of June, instead of May 15.  

U.S. Treasury Meeting with Financial Institutions:  Last Friday, Deputy Secretary of the Treasury Wally Adeyemo met with representatives of foreign financial institutions to discuss Treasury’s “unprecedented sanctions imposed on Russia for its war against Ukraine.”  Deputy Secretary Adeyemo highlighted the importance of financial institutions in implementing U.S. sanctions, and said that Treasury remained focused on stopping sanctions evasion.  According to press reports, he explained at the meeting the consequences for facilitating sanctions evasion, including providing material support to sanctioned entities, which could include being cut off from the U.S. and/or EU financial systems.

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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

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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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