On May 19, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an amended Directive 4, “Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation.” The purpose of the amendment
Russia
OFAC Again Extends Russia-Related General License No. 8 Regarding Transactions Related to Energy
On May 5, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued amended Russia-related General License No. 8G extending the authorization to conduct transactions involving Vnesheconombank, Bank Financial Corporation Otkritie, Sovcombank, Sberbank, VTB Bank, Alfa-Bank, Rosbank, Bank Zenit, Bank Saint-Petersburg, and the Central Bank of Russia that are related to energy…
Deputies of the G7 Enforcement Coordination Mechanism Discuss Russia Sanctions Evasion
On April 27, 2023, deputies of the Group of Seven (G7) Enforcement Coordination Mechanism met to discuss the need to increase enforcement of multilateral sanctions and export controls implemented since Russia’s invasion of Ukraine in February 2022 in order to deny Russia access to the materials it requires to equip its military and the revenue…
OFAC Publishes Alert Warning of Possible Evasion of the Russian Oil Price Cap
On April 17, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) published an Alert warning U.S. persons about possible evasion of the price cap set on Russian-origin oil (see Update of December 5, 2022) and Russian-origin petroleum products (see Update of February 8, 2023) pursuant to Executive…
OFAC and State Department Continue to Target Individuals and Entities Facilitating Russian Financial Transactions and Supporting Russia’s Defense Sector
On April 12, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced further efforts to deny Russia’s access to the international financial system through facilitators and their businesses. For example, OFAC has designated and sanctioned the “facilitation network” of Alisher Burhanovich Usmanov, who had previously been placed on OFAC’s Specially Designated…
BIS Adds 28 Entities to the Entity List for Supporting Russia’s Military/Defense Industrial Base
On April 12, 2023, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule in which it added 28 entities to the Entity List. The entities are companies located in Armenia , China, Malta, Russia, Singapore, Spain, Syria, Turkey, the United Arab Emirates (UAE), and Uzbekistan. Each was placed on the…
USTR Releases President Biden’s 2023 Trade Policy Agenda and 2022 Annual Report
On March 1, 2023, the Office of the United States Trade Representative (USTR) released President Biden’s 2023 Trade Policy Agenda and 2022 Annual Report. According to the report, the 2023 trade agenda will prioritize creating new opportunities for American workers and families, supporting the middle class, driving decarbonization, and creating good-paying jobs. Additionally, the…
Commerce, Justice and the Treasury Issue Joint Compliance Note on Evasion of Russia Sanctions and Export Controls
On March 2, 2023, the Departments of Commerce, Justice and the Treasury issued a joint Compliance Note cautioning financial institutions and multinational companies subject to U.S. jurisdiction to “be vigilant against efforts by individuals or entities to evade sanctions and export control laws.” The Compliance Note emphasizes the “unprecedented scope and scale” of sanctions against…
UPDATED: President Biden Issues Proclamations Increasing the Tariff Rates on Russian Aluminum to 200% and Significantly Increasing Rates on Other Russian Products
On the one-year anniversary of Russia’s invasion of Ukraine, President Joseph Biden on February 24, 2023, issued a Proclamation on Adjusting Imports of Aluminum Into the United States to implement: (1) effective March 10, 2023, a 200% import tariff on aluminum articles and derivative aluminum articles that are the products of Russia, and (2) effective…
BIS Adds 37 Entities to Entity List for National Security Risk Activities Involving Burma, China, Iran and Russia
- Three entities in Russia,

