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Jeffrey L. Snyder

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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…

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…

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…

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…

On October 7, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) simultaneously published a final rule strengthening the antiboycott regulations in Part 766 of the Export Administration Regulations (EAR) (the “Final Rule”), as well as a memorandum on the new rule’s implementation (the “Final Rule Memo”), issued by the Assistant Secretary…

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…

Two new rules announced by the U.S. Department of Commerce, Bureau of Industry and Security (BIS) strive to severely inhibit China’s progress in indigenously producing advanced semiconductors. Although advanced semiconductors are widely used for commercial applications, BIS cited serious concerns regarding China’s use of the technology for WMD and military applications, and enabling human rights…

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…

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…

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…