Russia Sanctions: This week the United Kingdom updated the listings for several sanctioned persons by making 17 amendments to designated individuals and 10 amendments to designated entities.  The amendments included revisions to dates of birth, addresses, and descriptions.

General Licenses: On August 5, 2022, the United Kingdom issued general license (“GL”) INT/2022/2055384.  The GL allows UK persons to use the retail banking services of credit institutions and financial institutions designated under Regulation 5 of the Russian Regulations to make or receive payments that are exclusively for the purpose of winding down business operations in Russia.  Authorized payments include the payment of “staff salaries, taxes, regulatory fees and other fees to official government bodies, and payment of bills or invoices.”  The GL includes a reporting requirement.  Any person making or receiving a payment pursuant to the GL must report to HM Treasury (i) the amount(s) and purpose of payments, (ii) the payment method used, and (iii) the date on which the payments were made.   

Enforcement: The U.S. Department of Justice (“DOJ”) obtained a seizure warrant (the “Seizure Warrant”) from the U.S. District Court for the Southern District of New York authorizing the seizure of an airplane (the “Airplane”) belonging to sanctioned Russian oligarch Andrew Skoch.  The Airplane is an Airbus A319-100, and is estimated to be worth more than $90 million.  OFAC designated Skoch as a Specially Designated National (“SDN”) in April of 2018.  The investigation was coordinated through DOJ’s Task Force KleptoCapture, which was established in March 2022 to enforce U.S. sanctions, export controls, and other economic countermeasures imposed by the United States in response to Russia’s invasion of Ukraine, including through criminal prosecutions and the seizure and forfeiture of assets.  In an affidavit in support of the Seizure Warrant, a Bureau of Industry and Security law enforcement agent claimed that the Airplane was subject to seizure and forfeiture as property involved in a money laundering transaction or attempted money laundering transaction.

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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.

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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.

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Photo of Jeffrey L. Snyder Jeffrey L. Snyder
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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

…

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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