On February 24, 2023, the United States and other G7 nations announced a number of new sanctions and export control measures coinciding with the one-year mark of Russia’s military invasion of Ukraine. Shortly after these expansive sanctions and export controls were announced, the Departments of Justice (“DOJ”), the Treasury (“Treasury”), and Commerce (“Commerce”) issued their

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 (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.
OFAC and OFSI Issue Licenses for Humanitarian Aid in Syria and Turkey
On February 6, 2023, two massive earthquakes of 7.8 and 7.6 magnitude struck Turkey and Syria, resulting in substantial physical damage and tremendous loss of life with over 40,000 deaths as of February 14, 2023. Non-governmental organizations, the United Nations, and other non-profits have mobilized efforts to assist in disaster recovery efforts. As the search…
Sanctions/Export Highlights [As of November 10, 2022]
UK Releases General License Permitting Agricultural Commodities Exports: On November 4, 2022, the UK’s Office of Financial Sanctions Implementation (“OFSI”) issued a new general license under its Russia sanctions regime. This license permits exporters of agricultural commodities and UK Department of International Trade License holders: (1) to receive funds and economic resources from any…
Sanctions/Export Highlights [As of November 03, 2022]
OFAC Guidance: On October 31, 2022, the Office of Foreign Assets Control (“OFAC”) published Frequently Asked Question (“FAQ”) 1094, confirming that Russian crude oil loaded onto a vessel at the port of loading for maritime transport prior to December 5, 2022, is not subject to a to-be-determined oil price cap, provided that the oil…
Sanctions/Export Highlights [As of October 27, 2022]
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…
Sanctions/Export Highlights [As of October 20, 2022]
New U.S. and UK Sanctions Partnership: On October 13, 2022, the Office of Foreign Assets Control (“OFAC”) and the UK’s Office of Financial Sanctions Implementation (“OFSI”) announced that they had concluded multi-day meetings in London involving technical exchange of information between the two sanctions authorities. The agencies have decided to enhance OFAC-OFSI cooperation further, including…
Sanctions/Export Highlights [As of October 13, 2022]
EU Updates FAQS to Address Energy Security: On October 7, 2022, the EU updated two FAQs clarifying the impact of Council Regulation 833/2014 on the import, purchase and transfer of listed goods. The EU clarified that Council Regulation 833/2014 prohibits the transfer of any listed goods if they originate in Russia or are exported from…
Sanctions/Export Highlights [As of October 6, 2022]
New U.S., UK, and EU Designations: On September 30, 2022, the U.S. designated 295 individuals and entities. The new designations included 14 persons in Russia’s military industrial complex, including Sinno Electronics Co. and Taco LLC, Chinese and Armenian suppliers, for their support of a Russian defense procurement firm. The U.S. also targeted two Russian…
Sanctions/Export Highlights [As of September 29, 2022]
UK Designates 89 Individuals and Three Entities: On September 26, 2022, in response to Russia’s “sham” referendums to annex four Russian-occupied regions in Ukraine, the UK designated an additional 92 individuals and entities. “Today’s sanctions will target those behind these sham votes, as well as the individuals that continue to prop up…
Sanctions/Export Highlights [As of September 22, 2022]
UK Amends Designation of Arkady Rotenberg: On September 16, 2022, the UK replaced the designation entry for Arkady Romanovich Rotenberg. The new entry description focuses on Mr. Rotenberg’s role in the construction of the Kerch Bridge, and the railway line on the bridge, which stretch from Russia to Crimea. Mr. Rotenberg was originally designated…