Tag: Russian sanctions

New U.S. Russia Sanctions Target Financial Support of Military-Industrial Base and Expand Ban of Seafood Imports

Anthony Rapa, George T. Boggs, Alan G. Kashdan, and Matthew J. Thomas ●

The Biden Administration recently issued the latest round of U.S. sanctions against Russia, focusing on (1) secondary sanctions applicable to foreign financial institutions (“FFIs”) that engage in certain transactions in support of Russia’s military-industrial base, and (2) the importation into the United States of certain Russian-origin seafood processed in third countries. The U.S. sanctions, issued December 22, 2023, follow the European Union’s twelfth package of sanctions against Russia, imposed on December 18, 2023.

As a result of the new sanctions, it will be important for FFIs to conduct export controls-related due diligence for any transaction with potential Russia exposure and for U.S. seafood importers to engage in supply chain tracing to ensure that imported products are not prohibited.

To effectuate the sanctions, President Biden issued a new executive order (“EO”) amending EO 14024 (providing for the imposition of sanctions against certain categories of Russia-related persons) and EO 14068 (prohibiting certain Russia-related imports, exports, and new investment). Furthermore, the U.S. Department of the Treasury, Office of Foreign Assets Control (“OFAC”) issued a determination (the “Critical Items Determination”) identifying categories of goods triggering secondary sanctions risks for FFIs and a determination (the “Seafood Determination”) identifying categories of seafood processed in third countries that are prohibited for import.

To read the full client alert, please visit our website. 

Law360: How Russia Sanctions Are Affecting Compliance

Law360, May 25, 2022

Anthony Rapa and Matthew J. Thomas ●

The wide-ranging sanctions and export controls that the U.S. and its partners have imposed on Russia in recent months pose complex compliance challenges for parties operating across borders, even when there is not a direct or obvious nexus with Russia.

Notably, the U.S. rules include restrictions relating to dealings with sanctioned persons, exports to Russia of a broad range of items, certain services, banknotes, certain imports, and new investment. Furthermore, the annexed Crimea region of Ukraine is subject to a comprehensive U.S. embargo, as are the so-called Donetsk People’s Republic, or DNR, and the Luhansk People’s Republic, or LNR.

This article provides practical guidance for compliance with such restrictions, which can affect commercial operations, investments, and processing of financial transactions.

You can read the full article on our website.

New York Law Journal: A Snapshot of Russia-Related Sanctions and Export Controls

New York Law Journal, May 19, 2022

Anthony Rapa and Matthew J. Thomas ●

Since Russia’s invasion of Ukraine on February 24, the United States and its partners have imposed a web of complex economic sanctions and export controls targeting Russia. These restrictions have broadened and intensified over the course of the conflict, at times at a dizzying pace.

At this point, the United States has not yet imposed a comprehensive embargo on Russia akin to the sanctions on Iran, Cuba, Syria, or North Korea. Rather, the Russia sanctions mainly are aimed at specific individuals, companies, and other entities. In addition, there are U.S. restrictions on certain types of imports (including energy), exports (including a broad range of goods and certain services), and new investment. Accordingly, the Biden Administration has ample opportunity to further expand restrictions to ramp up the impact on Russia’s economy.

This article provides a snapshot of the U.S. measures currently in place. It should be noted that the situation remains fluid, and the applicable restrictions are subject to change.

You can read the full article on our website.