One of the “most challenging” aspects of complying with U.S. and Western sanctions against Russia during the past year has been the service restrictions, which has created hurdles for companies trying to understand “exactly what types of activities fall within the scope of the covered services,” Sidley Austin said. In a Feb. 22 alert describing key compliance lessons from one year of Russia sanctions, the law firm said the service restrictions are “broad,” affecting everything from accounting to quantum computing, and not always carried out equally across various sanctions regimes.
The U.K. unfurled a new round of sanctions on Russia to mark the one-year anniversary of its invasion of Ukraine, the Foreign, Commonwealth and Development Office announced. The sanctions ban the export of "every item Ukraine has found Russia using on the battlefield to date" and place individual restrictions on another 92 individuals and entities. Sanctions target parties connected to state-owned nuclear power company Rosatom and Russian President Vladimir's Putin's closest allies, including his former chief of security and the CEO of Nord Stream 2, the FCDO said.
The G-7 and the EU last week committed to expanding sanctions against Russia and picking up enforcement efforts to counter Moscow’s sanctions evasion tactics. In a joint statement released Feb. 24, the group’s leaders said they “will maintain, fully implement and expand the economic measures we have already imposed” and establish an “Enforcement Coordination Mechanism to bolster compliance and enforcement of our measures and deny Russia the benefits of G7 economies.”
The Bureau of Industry and Security issued a temporary denial order last week suspending the export privileges of Russian company Radiotester OOO and owner Ilya Balakaev for illegally shipping “counterintelligence items” to Russia and North Korea. The denial order was released alongside a DOJ indictment charging Balakaev for smuggling devices used in foreign counterintelligence and military operations from the U.S. to Russia and “for the benefit” of Russia’s Federal Security Service and North Korea. Both Radiotester and Balakaev will be subject to a 180-denial order, barring either from exporting items or participating in transactions with items subject to the Export Administration Regulations.
The U.S. announced a new, sweeping set of export controls and sanctions last week to further hobble Russia on the one-year anniversary of its invasion of Ukraine, including additions to the Entity List, an expansion of industry sector restrictions on both Russia and Belarus, new export controls against Iran to address its drone transfers to Russia, and new financial sanctions against more than 100 people and entities. Many of the measures, which were announced alongside similar actions by U.S. G-7 allies, aim to “cut off the Russian defense industrial base and military from even low-technology consumer items,” the Bureau of Industry and Security said.
The U.S. is considering publicizing intelligence it believes shows China is deciding whether to send weapons to Russia for its war in Ukraine, The Wall Street Journal reported Feb. 22. The discussions within the Biden administration came before Feb. 25 U.N. Security Council meeting and a “number of closed-door appeals” to China coordinated among NATO members, the report said. Other Western countries in recent weeks have also “picked up on” intelligence that China may begin supplying weapons to Russia, but “it appears that China hasn’t yet made a final decision,” the report said.
The Bureau of Industry and Security announced a host of new export control actions aimed at further limiting Russia from sustaining its war effort against Ukraine, including additions to the Entity List, an expansion of the agency’s industry sector restrictions on both Russia and Belarus and new export controls against Iran to address its drone transfers to Russia. The measures, effective Feb. 24, add 86 new entities to the Entity List; place additional restrictions on commercial, industrial and luxury goods; impose new license requirements on “low-technology” items destined to Iran; create a new Iran Foreign Direct Product Rule, and more.
Japan and other G-7 countries should use the group’s trade ministers meeting later this year to push for a common set of export control standards across member states, which could help allied export control systems better respond to modern security and human rights issues, export control and technology policy experts said. In comments recently submitted to Japan’s Ministry of Economy, Trade and Industry, the experts said plurilateral controls by G-7 countries and other like-minded “techno-democracies” can address some issues the existing multilateral control regimes are hindered from tackling because of Russia’s membership (see 2211210005 and 2009290042).
House Foreign Affairs Committee Republicans are asking the Bureau of Industry and Security for information on its export enforcement and compliance efforts involving China, including steps to crack down on Chinese transfers of controlled U.S. technology to State Sponsors of Terrorism (SSTs). In a letter sent to BIS last week, Rep. Michael McCaul of Texas, chair of the committee, said he is concerned China’s “economic and trade ties” with terrorism sponsors is “undermining U.S. national security and foreign policy interests.” He and Rep. Michael Lawler, R-N.Y., asked BIS to provide information on recent Chinese export violations, licensing procedures, end-use checks and more by March 2.
The U.S. and its allies are planning a “renewed effort” to counter Russia’s sanctions evasion tactics, Treasury Deputy Secretary Wally Adeyemo said this week, speaking during a Feb. 21 event hosted by the Council on Foreign Relations. He said part of the effort will include new sanctions and export controls, more enforcement cooperation with allies and more direct conversations with companies that are still doing business with Russia.