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

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

On January 10, 2017, Senate Republicans and Democrats introduced bi-partisan legislation called the “Countering Russian Hostilities Act of 2017,” which would impose broad sanctions on Russia. The Act would codify the sanctions President Obama imposed in response to the Russian cyberattack on the United States to influence the 2016 U.S. Presidential election and the Ukraine-related sanctions President Obama issued in 2014. Importantly, the legislation introduces beefed up economic sanctions against Russia’s energy and financial sectors.
Continue Reading The Future of Russia Sanctions: The Awkward Edition

On July 16, the U.S. Department of Treasury, Office of Foreign Assets Control (OFAC) imposed new sanctions against Russia, which target the country’s financial, energy and defense sectors.  In a parallel action, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) added 11 parties to its Entity List based on their role in the destabilization of eastern Ukraine and the ongoing occupation of Crimea and Sevastopol.
Continue Reading CLIENT ALERT: United States Imposes New Sanctions and Export Restrictions Against Russian Banks, Companies, and Individuals

The pressure on Russia continues to build.  As we previously reported here and here, throughout March, the United States and other Western powers implemented a series of sanctions against individuals and entities deemed to be involved in the political destabilization of Ukraine.  Those sanctions were restricted to specific parties, including high ranking Russian and Ukrainian officials and – notably – one Russian bank.
Continue Reading Starving the Bear: The United States Restricts Exports to Russia

In response to Russia’s military presence in the Crimean region of Ukraine, President Obama issued an Executive Order (“EO”) on March 6, 2014, authorizing the blocking of property of individuals and entities involved in the political destabilization of Ukraine. The EO provides categories of persons subject to the sanctions but leaves the U.S. Treasury and State Departments to designate the specific persons covered by the EO.
Continue Reading The Gloves are Off: U.S. Sanctions Block Aggressors in Crimea

On March 5, 2014, the U.S. Department of Justice announced that it had frozen over $458 million of ill-gotten assets that former Nigerian dictator Sani Abacha and his co-conspirators had stashed in bank accounts across the globe.  The DOJ is seeking to recover almost $100 million more.  The largest-ever kleptocracy forfeiture action brought in the United States, this case is a victory for the Kleptocracy Asset Recovery Initiative, a program launched by the DOJ Criminal Division’s Asset Forfeiture and Money Laundering Section in 2010.  We wrote about the Initiative’s first-ever action here, brought in 2012, when the DOJ executed a forfeiture order of just over $400,000 against a former Nigerian governor.  And while the DOJ has seen great success in its actions against bribe-payers through the enforcement of the Foreign Corrupt Practices Act, initiatives to bring bribe-takers to justice have faced bumps in the road, probably because of the politically fraught and complex nature of such cases.
Continue Reading It Doesn’t Pay to Steal: In Largest Ever Kleptocracy Forfeiture Action, DOJ Seizes $458 Million