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Jeffrey L. Snyder

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Since 1986, Jeff's practice has concentrated on the U.S. regulation of international trade. Clients seek him out for troubleshooting and problem solving in cross-border transactions. Jeff advises on import, export, and sanctions laws. He develops approaches for multinationals to manage the impact of U.S. extraterritorial regulations. Jeff assists companies in day-to-day compliance with these laws, and with interventions — such as audits and investigations, and civil enforcement proceedings.

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Russia Sanctions: This week the European Union designated three additional individuals.  Two of the individuals are members of the Duma who undermined the territorial integrity, sovereignty, and independence of Ukraine by voting in favor of a resolution regarding the need to recognize the so-called Donetsk People’s Republic and Luhansk People’s Republic.  The other sanctioned…

UK Sanctions Removal and Other Amendments: On August 23, 2022, the UK delisted Mikhail Vladimirovich Razvozhayev, the Governor of Sevastopol, who had been subject to a UK asset freeze since late July 2022.  The UK published amendments for 42 other individuals and entities, primarily revising descriptions of the parties.

U.S. and UK Issue General …

UK Publishes General License for Energy for Mongolia: On August 16, 2022, the UK published General License INT/2022/2085212 for Mongolia energy payments.  The license permits payments to the Credit Bank of Moscow, Gazprombank, Sberbank, Rosbank PJSC, or any entity owned or controlled by these banks, for the purpose of making energy available for use…

Russia Sanctions: This week the United Kingdom updated the listings for several sanctioned persons by making 17 amendments to designated individuals and 10 amendments to designated entities.  The amendments included revisions to dates of birth, addresses, and descriptions.

General Licenses: On August 5, 2022, the United Kingdom issued general license (“GL”) INT/2022/2055384.  The…

In a report from April 2022, Washington, DC based-firm Horizon Advisory investigated the Xinjiang aluminum sector and reported how – alongside the textile, apparel, agriculture, and solar energy sectors in the region – this sector is at high-risk of forced labor exposure. The report found that the eight major aluminum companies operating in Xinjiang –…

EU Extends Sanctions Six Months: On July 26, 2022, the EU renewed restrictions on specific sectors of Russia’s economy until January 31, 2023.  This includes restrictions on finance, energy, technology and dual-use goods, industry, transport and luxury goods.

UK Designates 41 More Individuals and One Additional Entity: On July 26, 2022, the UK…

New UK Sanctions:On July 21, 2022, the UK introduced a new tranche of restrictions in the 14th amendment to its Russian Sanctions Regulations.  Several of the new restrictions are detailed below.

The UK prohibited UK persons from directly or indirectly providing accounting services, business and management consulting services, and public relations services to “…

U.S. General Licenses and Guidance: The Office of Foreign Assets Control (“OFAC”) issued four general licenses (“GLs”) this week.  In GL6B, OFAC expanded the authorizations in the previous GL 6A to also permit all transactions “related to…the production, manufacturing, sale, or transport of…agricultural equipment”, in addition to the previously-authorized transactions, including transactions relating to…

On June 28, 2022, the Financial Crimes Enforcement Network (“FinCEN”) and the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a joint alert (the “Alert”), urging financial institutions regulated under the Bank Secrecy Act (“BSA”) to remain vigilant of efforts by third parties to evade the extensive U.S. export controls imposed on…