On June 12, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced new measures targeting Russia’s financial infrastructure, including:Continue Reading OFAC Tightens Russia Sanctions; BIS Cracks Down on Diversion
The EU is going extraterritorial, and it is doing so through private contract. It is a pretty neat trick.Continue Reading E(U)xterritoriality of EU Sanctions: The No Russia Clause
On June 23, 2023, the EU released its 11th package of sanctions on Russia. This package is designed to improve enforcement with new anti-circumvention rules, new trade restrictions, and new designations. The anti-circumvention rules are quite a novel aspect and could result in the first extraterritorial reach of European sanctions.Continue Reading The EU’s 11th Sanctions Package: The Long(er) Arm of the Law
The United States and its allies are aiming to choke off the supplies that support the last vestiges of Russian industry. On May 19, 2023, the Bureau of Industry and Security (BIS) released new regulations implementing additional restrictions under the Export Administration Regulations (EAR) as well as corrections and clarifications on existing controls for Russia and Belarus.[1] Those additions build on recent export control regulations issued on February 24, 2023 (which we discuss here) and significantly expand controls over items that can be used in even basic electronics and manufacturing. The new regulations continue BIS’s push to leave very little that may be sent into Russia from the United States.Continue Reading Everything but the Kitchen Sink (and Maybe That Too!): New Export Controls on Russia Cover Whole Categories of Low-Level Commercial Electronic and Mechanical Equipment
In response to Russia’s ongoing aggression in Ukraine, both the United States and the European Union have imposed additional sanctions and further restricted exports to Russia and Iran. These new controls span many industries.Continue Reading Friday Development: New Sanctions and Export Controls to Address Russia’s Ongoing Aggression in Ukraine (Including the use of Iranian UAVs)
In response to Russia’s illegal declaration of annexations of Ukrainian territory, the United States and the European Union have imposed additional sanctions on Russia.Continue Reading U.S. and Allies Impose Additional Russia Sanctions After Sham Annexations
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
Updated as of March 3, 2022
Key Takeaways of EU and UK Recent Actions Against Russia and Ukraine Breakaway Regions
Updated as of February 25, 2022
Key Takeaways