Russia Sanctions: The U.S. today designated two key supporters of an extremist group called the Russian Imperial Movement (“RIM”) under the Specially Designated Global Terrorist program.  OFAC explained that “RIM and its supporters continue to exacerbate Russia’s war of aggression in Ukraine through their fundraising efforts.”  

The UK designated 12 individuals and entities under its Russian Sanctions regulations.  The individuals included Alexey Isaykin, the President of Volga-Dnepr Group; Vladimir Mikhailovich Gundyayev, the Primate of the Russian Orthodox Church; and several members of the “Salvation Committee for Peace and Order” in Kherson, Ukraine.

The UK also designated 4 individuals under its Chemical Weapons Sanctions regulations.  The individuals were involved in poisoning attacks directed at Alexei Navalny, a Russian opposition figure, and Sergei Skripal, a former Russian military officer.

The UK also made dozens of amendments to designated entities that revised dates of birth, addresses, AKAs, and descriptions.  The UK also published guidance explaining how the UK collects and collates data on designations

General Licenses: The U.S. issued general license (“GL”) 8C, which supersedes GL 8B.  The GL authorizes transactions related to energy prohibited by Executive Order (“EO”) 14024 that involve (1) State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank; (2) Public Joint Stock Company Bank Financial Corporation Otkritie; (3) Sovcombank Open Joint Stock Company; (4) Public Joint Stock Company Sberbank of Russia; (5) VTB Bank Public Joint Stock Company; (6) Joint Stock Company Alfa-Bank; (7) any entity in which one or more of the previously listed entities own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest; or (8) the Central Bank of the Russian Federation.  The revisions in GL 8C extend the expiration date of the GL from June 24, 2022 to December 5, 2022.

The UK issued GL INT/2022/1919908, which allows individuals to use retail banking services with credit or financial institutions designated under Regulation 5 of the Russia Regulations.  The payments must be intended for personal use, and the total value of payments made by an individual must not exceed £50,000.  The license will expire on September 10, 2022.

Enforcement: The U.S. issued an order temporarily denying all export privileges for Belavia Belarusian Airlines due to ongoing violations of the comprehensive export controls imposed on Belarus.  The airline had been providing flight services for passengers and cargo on U.S.-origin aircraft in violation of U.S. export controls.  Separately, Erik Woodhouse, a senior sanctions official with the State Department, stated that U.S. sanctions and export controls are having a “severe” impact on Russia. Notably, BIS has begun releasing to the public Charging Letters in export enforcement cases – these letters provide real time insight into BIS enforcement activity; here is the latest: https://efoia.bis.doc.gov/index.php/documents/export-violations/export-violations-2022/1373-scott-charging-charging-letter-6-7-2022/file In the past Charging Letters like this were released to the public only after the cases were settled.

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Photo of Frances P. Hadfield Frances P. Hadfield

Frances P. Hadfield is a counsel in Crowell & Moring’s International Trade Group in the firm’s New York office. Her practice focuses on forced labor and withhold release orders (WRO), import regulatory compliance, and customs litigation. She regularly advises corporations on matters involving…

Frances P. Hadfield is a counsel in Crowell & Moring’s International Trade Group in the firm’s New York office. Her practice focuses on forced labor and withhold release orders (WRO), import regulatory compliance, and customs litigation. She regularly advises corporations on matters involving customs compliance, audits, customs enforcement, as well as import penalties.

Frances represents clients before the U.S. Court of International Trade and the U.S. Court of Appeals for the Federal Circuit, as well as in proceedings at the administrative level. She advises corporations on both substantive federal and state regulatory issues that involve U.S. Customs and Border Protection, the Federal Trade Commission, Food and Drug Administration, and U.S. Fish & Wildlife in matters pertaining to product admissibility, audits, classification, import restrictions, investigations, marking, licenses, origin, penalties, and tariff preference programs.

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.