DOJ’s recent sanctions-related subpoenas of Credit Suisse Group and UBS Group are more evidence of the agency’s increasing “emphasis” on corporate enforcement, Rahman Ravelli said in an April 6 client alert. The agency launched a probe on both Swiss banks to examine whether they helped Russian oligarchs evade sanctions, Bloomberg reported last month, and Rahman Ravelli said the effort is part of a “wave of subpoenas” issued by DOJ in recent weeks.
Companies should be prepared for more “swift and persistent changes” to U.S. sanctions and export control regulations as the Biden administration continues to impose restrictions on Russia for its invasion of Ukraine, Barnes & Thornburg said in an April 4 client alert. The firm also said companies should prepare for U.S. government “inquiries into their transactions” even if they aren’t doing business in Russia or Belarus. “[T]hird-party intermediary risks are global,” it said. The Bureau of Industry and Society is one agency ramping up outreach to exporters amid a rise in new restrictions against Russia and China (see 2303240060).
The Treasury Department may be prioritizing enforcement of existing Russia sanctions rather than searching for new measures to impose, said Jay Shambaugh, Treasury’s undersecretary for international affairs. Shambaugh, speaking during an April 10 event hosted by the Brookings Institution, also said industry should expect the Biden administration to continue imposing national security-related trade restrictions on China.
Companies should expect the U.S. to devote “higher budgets” and increase interagency coordination to bolster U.S. sanctions and export control enforcement, which could lead to “previously unseen” compliance risks, Orrick said in a recent client alert. The firm pointed to DOJ’s plans to hire new export control and sanctions prosecutors (see 2303070023), the administration’s new disruptive technology strike force (see 2303220037), the joint compliance alert earlier this year that outlines methods Russia uses to circumvent trade restrictions (see 2303020054), and more.
The U.K. amended or corrected two entries under its Russia sanctions list and another under its Cyber sanctions list, according to the Office of Financial Sanctions Implementation. The entry for Volodymir Vasilyovich Saldo, founder of the Salvation Committee for Peace and Order in Kherson, was amended to add his address. The entry for Vladimir Konstantinovich Markov, manager for Gazprom, had a correction made to his date of birth. Under the Cyber sanctions list, OFSI amended the entry for Vitaliy Nikolayevich Kovalev to clarify use of an alias.
The European Commission updated its Russia sanctions FAQs on "export-related restrictions for dual-use goods and advanced technologies." According to the EU Sanctions blog, the FAQs were amended to show that the restrictions bar transit via the territory of Russia of dual-use goods and technology shipped from the EU. The new FAQs also update the Correlation Table that links prohibited goods with their Combined Nomenclature (CN) commodity codes.
The U.S. District Court for the District of Connecticut ordered Estonia-based exporter By Trade OU to forfeit about $826,000 in connection with the attempted export of a dual-use export-controlled item to Russia, DOJ announced. The company, along with a Latvia-based corporation, conspired to ship a jig grinder made in Connecticut to Russia.
Microsoft will pay more than $3.3 million combined to settle alleged export control and sanctions violations largely related to its foreign subsidiaries, the Bureau of Industry and Security and the Office of Foreign Assets Control said in a pair of news releases April 6.
The U.S. this week sanctioned Genesis Market, one of the world’s “largest illicit marketplaces,” for illegally selling stolen data, including usernames and passwords. The marketplace is “believed” to be based in Russia, the Office of Foreign Assets Control said, where it operates as one of the “most prominent brokers of stolen credentials and other sensitive information,” including information from U.S. and international companies. Cybercriminals also have used Genesis Market to target the U.S. government, OFAC said.
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