On December 7, 2022, the United States, along with the EU and other G7 nations, imposed a price cap of $60 per barrel on crude oil of Russian Federation origin (“Russian oil”), effective December 5, 2022 (see our related...more
On April 12, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published four new General Licenses (“GL”) (GL 62, GL 63, GL 64, and GL 65), revoked GL 15, and issued FAQ 1122 related to the...more
4/18/2023
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Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List
Russian “Exit Tax”. As of December 2022, the Russian Federation imposed new laws that could require U.S. persons to pay an “exit tax” prior to divesting assets located in the Russian Federation; any such payment could...more
On February 27, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule (the “Iran Final Rule”) imposing new export control measures against Iran caused by to its support of Russian...more
On February 24, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a series of new export controls related to restrictions on trade with Russia and Belarus. The Russia / Belarus final rule...more
On February 24, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) released a new determination targeting the metals and mining sector of the Russian Federation economy under Executive Order...more
On February 8, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published FAQ 1113 related to the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR Part 587 (the...more
On February 3, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a determination (“Price Cap on Petroleum Products of Russian Federation Origin”) pursuant to section 1(a)(ii), (1)(b)...more
On January 26, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) re-designated PMC Wagner (“Wagner Group”), a Russian private military company, as a significant transnational criminal...more
On January 17, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Venezuela-related General License (“GL”) 5J and amended FAQ 595....more
On January 17, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued three Russia-related General Licenses (“GL”) 6C, GL 28B, and GL 54A, and amended four FAQs (FAQ 982, FAQ 1054,...more
On January 9, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Venezuela-related General License (“GL”) 31B and amended FAQ 522, 547, 660, 679, and 680....more
Russia’s Response to Western Oil Price Cap and New OFAC Preliminary Guidance on Implementation of the Price Cap Policy for Petroleum Products of Russian Federation Origin...more
On December 15, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) (1) designated several individuals and entities to the Specially Designated Nationals and Blocked Persons (“SDN”) List,...more
On December 2, 2022, the United States, along with other G7 nations, including the European Union and Australia, adopted a price cap of $60 per barrel on seaborne crude oil of Russian Federation origin. The cap prevents firms...more
GL 13. On November 21, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) reissued General License (“GL”) 13C related to the Russian Harmful Foreign Activities Sanctions Regulations,...more
On November 18, 2022 the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License (“GL”) 54 related to the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR Part...more
On November 14, 2022 the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License (“GL”) 40C related to the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR Part 587...more
G7 leaders agreed last month to implement a price cap on Russian oil sales starting December 5, 2022. In conjunction with the G-7 agreement, on October 31, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets...more
U.S. Sanctions In response to Russia’s attempt to annex parts of sovereign Ukrainian territory, G7 Leaders issued a statement on September 23, 2022 condemning Russia’s sham referenda and noting their collective readiness to...more
A lot has happened since our last update. Apologies to our readers for the delay to publish this Update. Each time we were ready to go to press, OFAC published a new action. Following the recent United Nations General...more
On August 19 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) amended Russia-related General License (“GL”) 38A (GL 38A) and issued a new GL (GL 50) related to the Russian Harmful Foreign...more
On August 2, 2022 and August 3, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) (1) amended two Russia-related General Licenses (“GLs”): (GL 40A) / GL 40B) and (GL 43A), (ii) issued two...more
On July 22, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) (1) issued two new Russia-related General Licenses (“GL”) (GL 45 and GL 46), (2) published two new FAQs (FAQ 1071 and FAQ...more
On July 14, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued four Russia-related General Licenses (“GL”) (GL 6B, GL 25C, GL 30A, and GL 44), published three amended FAQs (FAQ 967,...more