Sanctions

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On June 27, 2022, President Joseph Biden issued a Presidential Proclamation announcing that the United States was increasing the duty rate to 35% ad valorem on certain products from Russia effective July 28, 2022. The White House indicated that this higher tariff will affect “more than 570 groups of Russian products worth approximately $2.3 billion”;…

Key Notes:

  • Effective June 21, 2022, the Uyghur Forced Labor Prevention Act (UFLPA) establishes a rebuttable presumption that all goods produced, mined or manufactured in the Xinjiang region of China or by certain entities designated to the UFLPA Entity List are produced with forced labor and prohibited from entry into the United States.
  • The prohibition

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On June 2, 2022, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule adding 71 entities located in Russia and Belarus to the Entity List in further response to Russia’s invasion of Ukraine. These entities have been determined by the U.S. government to be acting contrary to the national security…

On June 2, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated and blocked numerous additional Russian and related entities that are “key networks” relied upon by President Vladimir Putin and other Russian elites “to attempt to hide and move money and anonymously make use of luxury assets around the globe.”…

On May 27, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 8J, extending authorization until December 1 for certain activities previously authorized under General License 8I. General License 8J authorizes the continuation of transactions and activities “ordinarily incident and necessary to the limited maintenance of essential…

On May 23, 2022, the U.S. Departments of State, the Treasury, Commerce, and Labor issued a joint advisory for U.S. businesses operating in Sudan. The advisory highlights the risks associated with conducting business with Sudan’s state-owned enterprises (“SOEs”), which are effectively controlled by the Sudanese military since its seizure of power on October 25, 2021.…

On May 12, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Syria General License (GL) 22, which authorizes certain transactions, including processing or transfer of funds on behalf of third-country entities, otherwise prohibited under the Syrian Sanctions Regulations (SSR) that are ordinarily incident and necessary to activities in the…

The Department of the Treasury’s Office of Foreign Assets Control (OFAC) recently issued several Russia-related general licenses under the Russian Harmful Foreign Activities Sanctions Regulations, 31 C.F.R. Part 587 (RuHSR). These licenses authorize certain activities which would otherwise be prohibited under OFAC sanctions toward Russia:

GL 26A extends until July 12, 2022 existing authorizations for…

Key Notes:

  • Persons, including non-U.S. persons, providing accounting, trust and corporate formation, and management consulting services in Russia may be added to the SDN List.
  • U.S. persons are prohibited from providing these same services to Russian persons unless the recipient of the services is the subsidiary of a U.S. person.

The Department of the Treasury’s…

On May 5, 2022, the Treasury Department’s Office of Foreign Assets Control (OFAC) issued much anticipated Russia-related general license (GL) 31, “Authorizing Certain Transactions Related to Patents, Trademarks, and Copyrights.” GL 31 authorizes certain transactions otherwise prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR Part 587 (“RuHSR”) with respect to intellectual…