On April 29, 2022, the UK introduced new measures to prevent the provision of internet services to or for the benefit of designated persons.[1] These measures apply to the whole territory of the UK and to conduct by UK persons where that conduct is wholly or partly outside the UK. The designated entities or individuals (“Designated Persons”) can be found on the regularly updated UK Sanctions List with the tag “Internet Sanctions List”. To date, only V-Novosti and Rossiya Segodnya are designated under those authorities.

Continue Reading Introduction of internet-related Russia trade sanctions in the UK

Updated as of April 12, 2022

It has now been more than 40 days since the start of Putin’s brutal invasion of Ukraine. Today, following the recent revelations of the atrocities committed in Bucha, Ukraine by Russian armed forces, the United States – in coordination with the G7 and the EU – imposed new sanctions on Russia (see here). The sweeping new sanctions seek to further restrict Russia’s access to dollars and put economic pressure on Putin to end the war. The sanctions include a ban on all new investment in Russia as well as designations of Russia’s largest financial institutions (i.e., Sberbank and Alfa Bank), critical state-owned enterprises, and Russian government officials and their family members, including Putin’s children.

Continue Reading U.S. and Allies Impose Additional Severe Costs on Russia for Atrocities in Ukraine

The recent comprehensive economic sanctions by the U.S. and other nations against Russia has propelled the crypto community onto the geo-political stage in a major way. As with other forms of payment and methods of money transmission, cryptocurrency and cryptocurrency exchanges are at risk for exploitation by criminal actors, including those attempting to evade economic sanctions. Several attributes of cryptocurrencies that are usually touted in favor of the technology—pseudonymity, decentralization, digitalization—are now giving government officials, regulators, and lawmakers cause for concern in the sanctions climate. In response, leaders in the crypto community are voicing support of sanctions compliance, and citing aspects of the technology—traceability, immutability, visibility—in reassurance of it. As discussed below, there are several steps that crypto platforms can take to further efforts in blocking and detecting sanctions evasion activity on their platforms.

Continue Reading Crypto and Russia Sanctions: A Primer and Survival Guide For Crypto Companies

Updated as of March 9, 2022

Key Takeaways of OFAC (Treasury), BIS (Commerce), and State Actions

  • Major Russian Banks Blocked from the U.S. Financial System


Continue Reading Russian Risk: Transactions with Russian Banks and Exports to Russia Create Greatest Exposure Under New U.S. Ukraine-Related Sanctions

Updated as of March 3, 2022

Key Takeaways of EU and UK Recent Actions Against Russia and Ukraine Breakaway Regions

  • The EU adopted sanctions restrictions targeting financial institutions, other entities, and individuals, and imposing territorial restrictions on Donetsk and Luhansk. The sanctions also include broad export restrictions to Russia detailed below.
  • In the UK, Prime Minister Boris Johnson has promised and adopted a “massive package of economic sanctions” including asset freeze restrictions; potential exclusion of Russian banks from the UK financial system, including preventing access by such banks to GBP and clearing services in the UK; and dual-use export restrictions to Russia.


Continue Reading Russian Risk: Transactions with Russian Banks and Exports to Russia Create Greatest Exposure Under New EU and UK Ukraine-Related Sanctions

Updated as of February 25, 2022

Key Takeaways

  • On February 21, 2022, the White House issued a new Executive Order (EO) that imposes comprehensive sanctions


Continue Reading U.S., UK and EU Sanctions Over the Donetsk People’s Republic (DNR) and Luhansk People’s Republic (LNR) Regions of Ukraine

Key Takeaways

  • The proposed regulation would arm the EU with a counterstrike capability if non-EU countries take economic action against a Member State.
  • Where a Member State is subject to economic interferences from non-EU states that affect its legitimate sovereign choices.
  • The European Commission to take some or all of the following measures against the interfering state:
    • Impose tariffs;
    • Implement quotas;
    • Restrict access to EU financial markets; or
    • Reduce intellectual property protections[1]


Continue Reading Arming for a Trade War: The EU Proposes an Unprecedented Anti-Coercion Regulation

With Russian forces massing at the Ukrainian border, the U.S. and EU have been warning of severe economic sanctions. While we wait and watch this brinksmanship play out, it is worth considering how businesses, and particularly banks, might prepare for what comes next.

Continue Reading A Ruble Without a Cause: What Economic Sanctions on Russia May Mean for Your Business and Global Finance

Happy new year everyone. The government is shut down, but there has already been a flurry of activity in 2019 on the economic sanctions and embargoes front. Here is a summary of where we stand on various sanctions regimes.

Russia. On January 10, 2019, the Trump administration defended its decision to ease U.S. sanctions against companies connected to the Russian oligarch Oleg Deripaska. In 2017, the “Countering America’s Adversaries Through Sanctions Act” (CAATSA) passed Congress overwhelmingly and was signed into law by President Trump. As we blogged here and here, CAATSA codified strict Russia sanctions. It also allows Congress to block any termination of sanctions by the Executive. In December 2018, the Treasury department announced that it would lift sanctions on three of Deripaska’s companies: EN+ group, Rusal, and JSC EuroSibEnergo. Though Deripaska would continue to be subject to sanctions personally, Secretary Mnuchin reportedly told members of Congress in a briefing that the three companies had committed to “significantly diminish Deripaska’s ownership and sever his control.” Many lawmakers left the briefing unimpressed, and expressed concern that lifting sanctions would result in a tremendous financial benefit to Deripaska, whose designation by Treasury for sanctions last year reads like a mafia indictment. For now, it is unlikely that Congress is united enough to use its CAATSA powers to maintain the sanctions in the face of the Administration’s decision to lift them. But it is clear that Congressional Democrats intend to exercise their oversight powers when it comes to sanctions (or lack thereof) against Russia.
Continue Reading New Year Sanctions Roundup: Where Do We Stand?

A double agent. Nerve gas. Violations of international law. The recently imposed sanctions on Russia have all the makings of a James Bond movie but, unfortunately, those sanctions may cause some less-than-entertaining headaches for your business.

Why These Sanctions

On August 8, the U.S. State Department notified Congress it would impose new sanctions on Russia based on the U.S. Government’s determination that the Russian Government has used chemical and biological weapons in violation of international law. That determination was made under the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (“CBW”) after the Russian government’s use of the “Novichok” nerve agent in an attempt to assassinate UK citizen (and double agent to Russia and the UK) Sergei Skripal and his daughter Yulia Skripal.
Continue Reading The Latest U.S. Sanctions on Russia