Russia Sanctions: This week the European Union designated three additional individuals.  Two of the individuals are members of the Duma who undermined the territorial integrity, sovereignty, and independence of Ukraine by voting in favor of a resolution regarding the need to recognize the so-called Donetsk People’s Republic and Luhansk People’s Republic.  The other sanctioned person is a member of the Federation Council, which ratified the “Treaty of Friendship, Cooperation and Mutual Assistance between the Russian Federation and the Donetsk People’s Republic and between the Russian Federation and the Luhansk People’s Republic.”

Enforcement: The U.S. Department of Commerce issued a charging letter alleging that PJSC LUKOIL (“Lukoil”), a Russian multinational oil and gas corporation, violated the Export Administration Regulations (“EAR”) by reexporting a U.S. origin Boeing 737-7EM aircraft to Russia without the required reexport license.  Relatedly, the U.S. Department of Justice (“DOJ”) obtained a warrant to seize the aircraft.  The forfeiture action was coordinated through the DOJ’s Task Force KleptoCapture which was created to enforce sanctions, export controls, and economic countermeasures that the United States imposed in response to Russia’s invasion of Ukraine.  The U.S. District Court for the Southern District of Texas issued the warrant.  The court found that the airplane was subject to seizure based on probable cause of violation of the EAR.  The airplane is estimated to be worth $45 million. 

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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.

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.