Public U.S. companies should update their China-related risk disclosures to factor in a range of potential trade restrictions on the horizon, including possible U.S. sanctions against Beijing for aiding Russia and new outbound investment restrictions, said Carl Valenstein, a trade lawyer with Morgan Lewis.
The U.K. updated its industry guidance on its Russia maritime services ban and oil price cap, noting the cap will stay under review and will be updated subject to the agreement of the Oil Price Cap Coalition. It also explains that, for the maritime services ban, a person supplying or delivering goods by ship includes a person who owns, controls, charters or operates a ship on which those goods are being carried from or to which those goods are being transferred, the EU Sanctions blog said April 12.
The U.K. Office of Financial Sanctions Implementation issued a notice April 12 adding 10 people and four entities to its Russia sanctions regime. The new designations target various Russian business and banking executives and other people with ties to Russia, including Felix Evtushenkov, Tatiana Evtushenkova, Natalia Evtushenkova, Nariman Gadzhiev, Demetris Ioannides, Gulnara Kerimova, Oksana Marchenko, Vladimir Skoch, Varvara Skoch, Christodoulos Vassiliades. The four entities are Curzon Square Ltd., Hanley Ltd., Meritservus HC Ltd. and USM Holdings Ltd. OFSI also amended the entry for Nikolay Bortsov, member of Russia's State Duma.
The U.S. this week announced new Russia-related trade restrictions, adding 28 entities to the Commerce Department’s Entity List and more than 100 entries to the Treasury Department’s Specially Designated Nationals List. The measures target people and companies either operating in Russia, aiding the country’s war against Ukraine or helping Moscow evade sanctions.
The U.K.'s Office of Financial Sanctions Implementation renewed until Oct. 28 its legal services General License under the Russia sanctions regime (see 2210310020), the EU Sanctions blog reported this week. The renewed license, which was set to expire April 28, will again cap legal fees at $621,000, including value-added taxes, and will cap legal expenses at 5% of legal fees up to $31,000. The renewed license, which the blog said was outlined in a recent "letter to stakeholders" from the government, also clarifies that it is applicable in certain cases in which the "fees and / or expenses may exceed the legal fees and / or expenses caps." The license will not authorize legal fees for "defamation and similar cases," the blog said.
The Bureau of Industry and Security this week renewed the temporary denial order for Russian airline Ural Airlines, whose export privileges were suspended for 180 days in October after BIS said it violated U.S. export controls by flying multiple aircraft to Russia without required licenses (see 2210170009). BIS said Ural continues to fly planes in violation of the Export Administration Regulations, including flights within Russia and to and from Kyrgyzstan and Tajikistan. The agency renewed the order for another 180 days from April 10.
Export Compliance Daily is providing readers with the top stories from last week in case you missed them. You can find any article by searching for the title or by clicking on the hyperlinked reference number.
The U.S. announced new measures against people and companies helping Russia evade sanctions, adding 28 entities to the Commerce Department’s Entity List and more than 50 new entries to the Treasury Department’s Specially Designated Nationals List. The Entity List additions, effective April 12, include companies in China, Armenia, Malta, Russia, Singapore, Spain, Syria, Turkey, the United Arab Emirates and Uzbekistan, all of which have supported Russia’s military or defense industrial base. New designations imposed by Treasury and the State Department target people and companies operating in Russia or that are aiding Moscow's war effort and its imports of “critical technologies."
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).