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).
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.