The EU this week adopted new sanctions and export controls against Russia in an effort to tighten existing restrictions against the country for its war in Ukraine. The package imposes new bans on the purchase, import or transfer of gold originating in Russia and restricts more exports of dual-use technologies. The measures also extend the EU’s port access ban to better limit Russia’s ability to evade sanctions and expand the scope of restrictions surrounding certain deposits.
Ivan Komaritsky, former corporate regulatory attorney at DLA Piper, has joined Rimon PC as counsel in the New York office, the firm announced. Komaritsky's practice centers around Foreign Corrupt Practices Act, Committee on Foreign Investment in the U.S. and U.S. economic sanctions matters. Throughout his career, Komaritsky has conducted internal investigations and FCPA corporate audits in countries around the globe, including in Russia, the Middle East, Eastern Europe and Southeast Asia, the firm said.
The U.K. adopted an amendment to its Russian sanctions regime that alters the designation criteria for listing an individual or entity. The new criteria expand the definition of "involved in obtaining a benefit from or supporting the Government of Russia," to include working as a "manager" of or "holding the right, directly or indirectly," to nominate a director, trustee or equivalent of a Russian government-affiliated entity; an entity conducting business as a government affiliate; or an entity conducting business of economic significance to the Russian state.
The Senate is making progress on bipartisan legislation that would give the administration stronger authorities to investigate, prosecute and seize the assets of sanctioned Russian oligarchs, including in cases of sanctions or export control evasion. The proposals received broad support this week from Senate Judiciary Committee members, who said DOJ’s powers should be expanded and bolstered to better punish Russian war crimes.
The U.K.'s Office of Financial Sanctions Implementation and its National Crime Agency issued a "Red Alert," titled "Financial Sanctions Evasion Typologies: Russian Elites and Enablers." The alert says sanctioned parties are using various techniques to skirt sanctions, including transferring assets to proxies. OFSI and NCA laid out the offenses that can apply to individuals or entities aiding sanctions circumvention. The alert contains a list of "indicators" of sanctions evasion and industry recommendations.
The U.K. adopted further Russian sanctions in an amendment to its restrictions that came into force July 15. The changes relate to trade in maritime goods and technology, military goods and technology with non-Russian-government controlled Ukrainian territory, defense and security goods, interception and monitoring services, banknotes, jet fuel and fuel additives, and goods that generate significant revenues for Russia.
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The Bureau of Industry and Security should harmonize the Entity List with other lists across various agencies to better capture foreign companies that should be subject to strict trade restrictions, lawmakers told BIS Undersecretary Alan Estevez this week. Others said BIS has failed to blacklist Chinese military companies that deserve placement on the Entity List, allowing the Chinese government to continue to buy sensitive American technologies.
The U.K. updated its Russia sanctions regime in a July 15 notice. The Office of Financial Sanctions Implementation dropped two names from the sanctions list, amended three others and corrected one more. OFSI removed Didier Casimiro, who was just designated in March (see 2203240016) and Zeljko Runje from the sanctions list; amended the entries for Sergei Ivanovich Saenko, Vladimir Leonidovich Sivkovich and Oleg Anatolyevich Voloshyn; and corrected the entry for Alrosa, a Russian diamond mining company.
The European Commission on July 15 adopted a joint proposal for new measures to uphold the effectiveness of the EU's six sanctions packages against Russia following its invasion of Ukraine, the commission announced. Dubbed the "maintenance and alignment" package, it includes a new import ban on Russian gold, reinforces dual-use and advanced technology export controls, strengthens reporting requirements to shore up asset freezes, clarifies the scope of some sanctions and extends current sanctions until January 2023. “Russia's brutal war against Ukraine continues unabated," EC President Ursula von der Leyen said. "Therefore, we are proposing today to tighten our hard-hitting EU sanctions against the Kremlin, enforce them more effectively and extend them until January 2023. Moscow must continue to pay a high price for its aggression.”