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An overview on new Russian sanctions and export controls issued by the U.S. (OFAC and BIS) and the UK focusing on the Russian financial, military, and LNG industries.

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Feb. 23, 2024–Today, following the death of opposition politician and anti-corruption activist Aleksey Navalny, and after two years of Russia’s unprovoked and unlawful full-scale invasion of Ukraine, the Commerce Department’s Bureau of Industry and Security (BIS) imposed additional export restrictions on 93 entities under 95 entries in Russia and seven other destinations. Sixty-three of the…

On September 28, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), alongside the UK, Australia, Canada, New Zealand (termed the “Export Enforcement Five” or “E5,”), as well as the EU, issued new guidance with recommended best practices to help prevent a list of “high-priority items” from being diverted to Russia. 

These…

From September 30, 2023, new EU and UK sanctions will come into effect targeting the imports of specified iron and steel products which are processed in third countries and incorporate Russian-origin iron and steel inputs. Importers will need to declare upon import whether the imported goods are compliant (and be prepared to provide evidence demonstrating…

Russia is reportedly unlikely to extend the Black Sea Grain Initiative, following negotiations in May to extend the deal past July 18th, which is the current deadline for all parties to either extend or collapse the deal.  The Black Sea Grain Initiative was initially brokered by the United Nations and Turkey between Russia…

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…

Russia Sanctions: This week the United Kingdom designated several additional individuals, primarily for contributing to the spread of disinformation about Ukraine and promoting Russian actions in Ukraine, or for their affiliation with organizations that have spread disinformation relating to Ukraine, such as SouthFront and NewsFront.  The United Kingdom also designated United World International, an…

Russia Sanctions: This week the United States designated dozens of additional entities and individuals as Specially Designated Nationals (“SDNs”).  Notable designations included State Corporation Rostec (“Rostec”), a large Russian state-owned company that operates in the automotive, defense, aviation, and metal industries; individuals who were part of a covert procurement network linked to Russia’s Federal…