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Caroline E. Brown is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s White Collar & Regulatory Enforcement and International Trade groups and the steering committee of the firm's National Security Practice. She provides strategic advice to clients on national security matters, including anti-money laundering (AML) and economic sanctions compliance and enforcement challenges, investigations, and cross border transactions, including review by the Committee on Foreign Investment in the United States (CFIUS) and the Committee on Foreign Investment in the U.S. Telecommunications Services Sector (Team Telecom).

Caroline brings over a decade of experience as a national security attorney at the U.S. Departments of Justice and the Treasury. At the U.S. Department of Justice’s National Security Division, she worked on counterespionage, cybersecurity, and counterterrorism matters and investigations, and gained unique insight into issues surrounding data privacy and cybersecurity. In that role, she also sat on both CFIUS and Team Telecom and made recommendations to DOJ senior leadership regarding whether to mitigate, block, or allow transactions under review by those interagency committees. She also negotiated, drafted, and reviewed mitigation agreements, monitored companies’ compliance with those agreements, and coordinated and supervised investigations of breaches of those agreements.

Sixth Round of EU Sanctions

As previewed in last week’s weekly highlights, the EU published a new round of sanctions on June 3, 2022, which includes a wide range of new restrictions.  Key provisions are summarized below.

The EU now prohibits the purchase, import, or transfer of Russian-origin crude oil and certain petroleum products.  Although

Russia Sanctions:  The UK designated 63 individuals this week, including several war correspondents embedded with Russian forces in Ukraine that work at Channel One, a major state-owned media outlet in Russia.  The UK also designated one entity, Evraz PLC, a UK-incorporated holding company of a multinational steel manufacturing and mining company group.  Additionally, the

Russia Sanctions:  The UK designated 63 individuals this week, including several war correspondents embedded with Russian forces in Ukraine that work at Channel One, a major state-owned media outlet in Russia.  The UK also designated one entity, Evraz PLC, a UK-incorporated holding company of a multinational steel manufacturing and mining company group.  Additionally, the

Russia Sanctions:  There were limited developments this week.  There has been speculation that the EU would release its sixth round of sanctions against Russia, but no updates have been reported thus far.  The new package of sanctions is still expected soon.  The U.S. and UK also did not expand their list of designations this

Russia Sanctions:  The UK and EU each made over 200 additional designations.  The EU designated several banks that the US previously had sanctioned, including Bank Otkritie, Novicombank, Sovcombank, and VTB Bank.  Both the EU and the UK designated several oligarchs including Alexander Petaykin (associated with Trans Stroy), Evgeny Zubitskiy (Industrial Metallurgical Holding), Grigory Berezkin

Russia Sanctions:  Last Friday, the U.S. (BIS) added a number of entities to the Entity List citing their support of the Russian and Belarusian militaries.  Over the April 1 weekend, the world began to learn of the atrocities in Bucha.  The U.S., UK, and EU have since responded with a number of new sanctions

As the U.S. government continues to ratchet up sanctions in response to the Russian invasion of Ukraine, public reporting suggests there may be a new target in the sites of U.S. sanctions authorities: Kaspersky Labs (Kaspersky), the popular Russian cybersecurity and antivirus company. Any sanctions imposed by the Department of Treasury’s Office of Foreign Assets

Russia Sanctions:  As the war enters its fifth week, the U.S. and UK continue to expand the restrictions and add to the list of designated individuals and entities.  Relative to sanctions and other prohibitions previously announced, there were few developments over the past week, but additional targeted sanctions may be forthcoming should the Russian

Russia Sanctions:  The U.S., EU, and UK continue to apply pressure on Russia through the implementation of additional sanctions.  The UK instituted the most significant additional sanctions this week, designating more than 350 persons.  The EU also prohibited engaging in transactions with an identified list of Russian state-owned companies and their subsidiaries outside of

Russia Sanctions:  The U.S., EU, and UK continue to apply pressure on Russia through new sanctions on oligarchs and politicians and restrictions on exports.  A number of other countries have implemented similar measures and continue to widen the scope of such prohibitions as the invasion continues.  On a more limited scale, Belarus has also