On April 29, 2022, the UK introduced new measures to prevent the provision of internet services to or for the benefit of designated persons. 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.
On May 6, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated a cryptocurrency mixer, Blender.io, as a Specially Designated National (SDN). That sanction follows a series of enforcements and sanctions which we have previously discussed here and here.…
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
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.
Updated as of February 25, 2022
- On February 21, 2022, the White House issued a new Executive Order (EO) that imposes comprehensive sanctions
- BIS added 33 Chinese companies to the Unverified List.
- The UVL places lesser restrictions designees than an Entity List or Sanctions designation
- BIS may not have been able to verify the entities because of new Chinese laws restricting compliance with extraterritorial laws; creating a potential conflict of laws for these and other companies.
- 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
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
- U.S. Customs halts the import of silica-based products from made by Hoshine Silicon Industry Co. because the products are suspected of being produced using forced labor.
- For future imports of solar energy equipment sourced from Xinjiang, China, the United States may use Withhold Release Orders (WROs) to block entry into the United States if there is reasonable suspicion of forced labor in the supply chain.
- The renewables industry is working together and with regulators to find ways to certify its supply chains are free of forced labor.
- New law could penalize companies for complying with U.S. sanctions.
- Penalties include designation to China’s new “Unreliable Entity” list.
- Statements against the new laws could also be penalized, restricting the capacity of counsel to advise freely on compliance with U.S. sanctions and Chinese countermeasures.
On June 10, 2021, China enacted the Anti-Foreign Sanctions Law (“AFSL”), aimed at punishing countries that impose anti-China sanctions and the companies that comply with those sanctions. The law is effective immediately, and applies to any sanctions imposed against China, Chinese entities, or Chinese individuals by any third country (excluding sanctions adopted by the United Nations).
The AFSL comes in addition to the Measures on Blocking Unjustified Extraterritorial Application of Foreign Legislation (the Blocking measures) issued earlier this year. Those measures were mainly address the extraterritorial effect of U.S. sanctions against China, by punishing companies that comply with U.S. sanctions.
Continue Reading Counterpunch: China Adopts Landmark Anti-Sanctions Statute to Stop U.S. Sanctions Effects Overseas
In May 2018 the United States announced the reinstitution of sanctions against Iran that had previously been lifted pursuant to the Joint Comprehensive Plan Action (“JCPOA”).
Continue Reading The EU – U.S. Sanctions Dilemma: The Advocate General of the European Court of Justice Weighs in