Feb. 23, 2024–Today, following the death of opposition politician and anti-corruption activist Aleksey Navalny, and after two years of Russia’s unprovoked and unlawful full-scale invasion of Ukraine, the Commerce Department’s Bureau of Industry and Security (BIS) imposed additional export restrictions on 93 entities under 95 entries in Russia and seven other destinations. Sixty-three of the entities are based in Russia, eight in the People’s Republic of China, sixteen in Turkiye, four in the United Arab Emirates (UAE), two in the Kyrgyz Republic, and one each in India and South Korea. More than 50 of the entities added to the list today will also receive a “footnote 3” designation as Russian-Belarusian military end users. A footnote 3 designation subjects these entities to some of the most severe restrictions under the Export Administration Regulations (EAR) by expanding U.S. jurisdiction to reach a greater scope of non-U.S. made item if ultimately destined to these entities.

Additionally, the Department of Treasury’s Office of Foreign Assets Control (OFAC) has announced that it is also sanctioning almost 300 individuals and entities relating to Russia’s invasion of Ukraine and the death of Aleksey Navalny. Treasury is designating targets including National Payment Card System Joint Stock Company, a major cog in Russia’s financial infrastructure and the state-owned operator of Russia’s Mir National Payment System; more than two dozen third-country sanctions evaders in Europe, East Asia, Central Asia, and the Middle East; and hundreds of entities in Russia’s military-industrial base and other key sectors.  In all, OFAC today targeted 26 third-country entities and individuals in 11 countries, including the People’s Republic of China, Serbia, the United Arab Emirates, and Liechtenstein. You can find the full BIS announcement of today’s actions here, while the OFAC announcement can be found here.

Crowell & Moring, LLP continues to monitor developments with regard to the Entity List and their potential impact on customers and businesses going forward.