On February 21, 2023, just a few days before February 24, which marks the one-year anniversary of Russia’s invasion of Ukraine, Deputy Secretary of the Treasury Wally Adeyemo spoke on the Biden administration’s “comprehensive strategy to support Ukraine” including ongoing efforts to deny Russia’s ability “to use the money they have to buy the weapons they need” and “to reduce the revenues that President Putin can use to fund his war of choice and prop up Russia’s economy.” Going forward, Deputy Secretary Adeyemo indicated that U.S. export controls and sanctions will continue to prevent Russia from accessing the equipment it needs and that sanctions “will make it harder for the Kremlin to use the remaining resources Russia can access to pay for the weapons they need.”

Adeyemo’s speech provides an overview of the multilateral sanctions and export control that have been put in place by the United States and a coalition of more than 30 nations, and continued efforts to isolate Russia. He stated that the coalition “will force those that fail to implement our sanctions and export controls to choose between their economic ties with our coalition of countries — representing more than half of the world’s GDP — or providing material support to Russia, an economy that is becoming more isolated every day.” While providing no specific actions or further sanctions, Adeyemo indicated that a next step would be countering Russia’s efforts to evade sanctions. These efforts will focus on three elements:

  • Continuing to work closely with allies and partners, especially in the G7 and EU, and using “all of our economic tools to give countries, companies, and individuals a choice: to do business with a coalition representing half of the global economy, or to provide material support to Russia.”
  • Identifying and eliminating “specific channels through which Russia attempts to equip and fund its military” by denying Russia access to dual-use goods being repurposed and used for the war and cutting off manufacturing facilities from inputs needed to fill Russia’s military production gaps. 
  • Pressuring companies and jurisdictions known to be allowing or facilitating evasion including “several of Russia’s neighbors” and other countries who have condemned the invasion of Ukraine but “are falling short of their obligations to enforce the sanctions” the U.S. and wider coalition have imposed.

Additional sanctions are expected as the anniversary date of Russia’s invasion approaches. Adeyemo closed his remarks by stating that the United States is “committed to continuing to support the people of Ukraine and to redoubling our efforts to hold Russia accountable—especially by countering efforts to evade our sanctions.”

Photo of Scott E. Diamond** Scott E. Diamond**

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor…

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor compliance, corporate anti-boycott and antibribery compliance, national security investigations, and foreign direct investment in the United States.

**Not licensed to practice law.

Photo of Samir D. Varma Samir D. Varma

Samir advises multinational corporations on export controls, economic sanctions and customs, and counsels individuals and corporations on the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws. He represents clients in enforcement actions before U.S. regulatory agencies and conducts corporate internal investigations.

Photo of Francesca M.S. Guerrero Francesca M.S. Guerrero

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some…

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some of their most challenging international transactions, involving dealings in high-risk jurisdictions or with high-risk counterparties. Francesca also counsels companies through all phases of internal investigations of potential trade and antibribery violations and represents companies across industries before related government agencies.