UK Sanctions Removal and Other Amendments: On August 23, 2022, the UK delisted Mikhail Vladimirovich Razvozhayev, the Governor of Sevastopol, who had been subject to a UK asset freeze since late July 2022.  The UK published amendments for 42 other individuals and entities, primarily revising descriptions of the parties.

U.S. and UK Issue General Licenses:

  • On August 19, 2022, OFAC issued General License (“GL”) 50.  The license authorizes all transactions ordinarily incident and necessary to (1) the closing of an account of an individual, wherever located, who is not a blocked person (“the account holder”), held at a financial institution blocked pursuant to Executive Order (“EO”) 14024; and (2) the unblocking and lump sum transfer of all remaining funds and other assets in the account to the account holder, including to an account of the account holder held at a non-blocked financial institution.  This license currently has no expiration date.
  • On August 19, 2022, UK General License INT/2022/1845976 took effect.  The license permits a Crown Servant, Contractor, Family Member or Visiting Family Member, as defined in the license, to carry out activities in their personal capacity in Russia, which would otherwise be prohibited by regulations 11-15 and 17A of OFSI’s Russia Regulations.  This license currently has no expiration date.
  • On August 22, 2022, the UK published General License INT/2022/2104808.  The license permits certain banks to take the payment of, or deduct, bank “Service Fees” from accounts frozen under OFSI’s Russia Regulations, such as fees arising from the routine maintenance of those accounts, with the specific scope provided in the license.  This license currently has no expiration date.

U.S. and UK Amend General Licenses:

  • On August 19, 2022, the U.S. issued GL 38A, which replaced GL 38.  General License 38 authorizes transactions incident and necessary to the processing of pension payments to U.S. persons, including transactions where funds are processed by financial institutions blocked pursuant to EO 14024.  General License 38A expands the scope of authorization to include payments to non-U.S. persons not located in Russia.
  • On August 22, 2022, the UK amended General License INT/2022/1280876, which allows VTB Capital plc, and any entity owned or controlled by: (1) VTB Capital plc incorporated in the United Kingdom; (2) Sberbank CIB (UK) Ltd. (“Sberbank UK”); or (3) any entity owned or controlled by Sberbank UK incorporated in the UK (together, the “UK Subsidiaries”) to make payments for their “basic needs” and related to Insolvency Proceedings of the UK Subsidiaries, as defined in the license.  This general license was amended to permit payments related to: (1) the basic needs of VTBC Asset Management International Limited and its Insolvency Proceedings; and (2) the basic needs of VTB Bank (Europe) SE (“VTBE”), and any entity owned or controlled by VTBE incorporated in Germany.

Seven EU Member Foreign Committee Chairs Call for Stronger Sanctions: On August 25, 2022, the Chairs of the Foreign Affairs Committees of Estonia, Latvia, Lithuania, the Czech Republic, Poland, Finland, and Denmark issued a joint statement that unequivocally condemned Russia’s actions in Ukraine and urged additional sanctions on Russia.  The nations also requested that EU members and Western allies “immediately suspend tourism and limit the issuance” of tourist visas for Russian citizens.

U.S. Department of Commerce, Bureau of Industry and Security (“BIS”) Press Release Summarizes Russia/Belarus-Related Export Controls: On August 25, 2022, BIS released a statement summarizing various export controls restrictions BIS has implemented since Russia’s invasion of Ukraine.  It lists a number of actions taken against Russia and Belarus, including the issuance of over a dozen regulations, which it said had resulted in a decrease of 97 percent by value of U.S. exports of newly-controlled items to Russia and Belarus.  BIS also highlighted actions it has taken with the U.S. Department of Justice, and its first-ever joint alert with the Financial Crimes Enforcement Network identifying export controls evasion risks for financial institutions.

U.S. State Department Publishes International Sanctions Fact Sheet: On August 22, 2022, the U.S. Department of State published an article regarding Kremlin-backed disinformation relating to Ukraine.  The article disputed Russia’s claim that international sanctions will not significantly impact Russia, and its assertion that sanctions are harming the West more than Russia.  “Economically, the sanctions we’ve imposed on Russia to end its aggression are having a powerful and also growing effect,” said Secretary of State Antony Blinken.  “Now, Moscow has been cherry-picking economic data to support President Putin’s insistence that everything is fine and the Russian economy is going strong.  It’s simply not true.”

Turkey Business Association Warned of Possible U.S. Sanctions: According to media reports, U.S. Deputy Treasury Secretary Wally Adeyemo sent a letter to both the Turkish Industry and Business Association (“TUSIAD”) and the American Chamber of Commerce highlighting that Turkish companies risked facing sanctions if they conducted business with sanctioned Russian persons.  This follows an August 19, 2022, discussion between Secretary Adeyemo and Turkey’s Deputy Finance Minister about U.S. concerns that Russian entities and individuals may use Turkey to evade U.S. and international sanctions.

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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 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.