Russia Sanctions: This week the United Kingdom designated several additional individuals, primarily for contributing to the spread of disinformation about Ukraine and promoting Russian actions in Ukraine, or for their affiliation with organizations that have spread disinformation relating to Ukraine, such as SouthFront and NewsFront.  The United Kingdom also designated United World International, an online news site that promotes pro-Russian disinformation.  Additionally, the United Kingdom made dozens of amendments to and removed a handful of individuals from the UK sanctions list.

The United States made one amendment to the Specially Designated Nationals (“SDN”) list by updating the a.k.a. information for the previously designated Belarussian Oil Trade House. 

Separately, news reports indicate that the EU is considering additional sanctions on Russian individuals and on Russian gold in the coming weeks, following similar actions taken by several G7 countries at the end of June 2022.

General Licenses: The United Kingdom issued three general licenses (“GLs”).  GL INT/2022/1947936 allows (i) activities to ensure the timely delivery of humanitarian assistance activity in relation to the conflict in Ukraine and non-government controlled Ukrainian territory and (ii) activities that support basic human needs in relation to the conflict in Ukraine and non-government controlled Ukrainian territory.  The GL specifies that funds or economic resources that are “owned, held or controlled” by a UK “Designated Person” may not be used to perform these activities, but exempts funds that are controlled by a “Designated Financial Institution” so long as the funds are not “owned, held or controlled by any other Designated Person or where the transfer of funds is otherwise licensed.”  GL INT/2022/1976232 authorizes wind-down transactions involving the National Bank of Belarus and the Ministry of Finance of Belarus until August 4, 2022.  Finally, GL INT/2022/1976332 permits dealing with certain transferable security or money-market instruments that are prohibited by Section 15A(2A) of the Belarus Regulations.  It also permits granting and entering into arrangements to grant Category C loans prohibited by section 15B(5) of the Belarus Regulations.[1]  This GL is valid until July 12, 2022.

Proposed Russian Oil Price Cap Update: Media reports indicate that the United States and its allies have continued discussions about capping the price of Russian oil.  These reports state that these countries are discussing ways to cap the price between $40 and $60 (USD) per barrel and continue to meet regularly to discuss this topic. 

BIS Updates: The U.S. Department of Commerce Bureau of Industry and Security (“BIS”) released materials from its annual export controls update conference.  The released documents include a presentation on 2022 Russian sanctions. 

[1] UK guidance for Republic of Belarus sanctions provides that: “a loan or credit on or after 5 July 2022 with a maturity exceeding 30 days granted to a person connected with Belarus,” subject to certain exclusions, “is classed as a category C loan.”

Tags: export, Russia, Sanctions
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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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Photo of Rachel Schumacher 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.

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