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 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

Sanctions Designations:

  • U.S. Designates Numerous Individuals and Entities: On September 15, 2022, the U.S. added a number of individuals and entities to the Specially Designated Nationals and Blocked Persons (“SDN”) List.  The sanctions target Russia’s financial system, including the heads of Russia’s state-run card payment system (NSPK), central securities depository, stock exchange’s clearing

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

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