New U.S. Designations: On October 26, 2022, the U.S. Department of the Treasury’s Office of Foreign Asset Control (“OFAC”) designated nine individuals and twelve entities for their involvement in the Russian Federation’s corruption and influence campaign in Moldova.  The designations included Igor Yuryevich Chayka, and Ivan Alesksandrovich Zavorotnyi, an associate of Chayka, for their actions related to election interference in Moldova.  Both men own various Russian-located entities, which were also designated.  In addition, OFAC designated Aleksei Valeryevich Troshin and the National Engineering Corporation (NIK) for their involvement in cybercrime.

EU Updates Guidance on Russian Sanctions: On October 24, 2022, the European Commission added five new FAQs to their guidance on business services prohibitions under the Russian Sanctions regime.  The new FAQs lay out the scope of prohibited activities classified under IT consultancy services, architectural and engineering services, and legal advisory services.  However, the Commission clarified that certain services “strictly necessary” for the termination of non-compliant contracts by January 8, 2023 are excluded from these prohibitions.  The new guidance additionally included a table providing an overview of prohibited services and any relevant exemptions.

EU Leaders Discuss Additional Sanctions on Iran and Belarus: Brussels hosted a summit for European Union leaders on October 20 and 21, 2022, where the European Council demanded Russia “immediately, completely, and unconditionally” withdraw all of its military forces from Ukraine.  The Council also called on Belarusian authorities to stop enabling Russian forces, noting that the EU remains ready to impose additional sanctions against Belarus if needed.  During the summit, European leaders also discussed imposing wider sanctions on Iran for its involvement in supplying weapons to Russia and for the ongoing civil rights abuses in Iran.

BIS Under Secretary Suggests Additional Export Controls on the Way: At an event hosted by the Center for a New American Security, Under Secretary of Commerce for Industry and Security Alan Estevez discussed the recent BIS controls aimed at restricting exports of advanced technologies to both China and Russia.  He noted that additional controls were likely to come “in the near term,” and would include a focus on emerging technologies, such as quantum information science, biotechnology, and artificial intelligence algorithms.

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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

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.