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
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
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
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
On June 14, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Russia-related General License (“GL”) 8C (replacing GL 8B), which extends the temporary wind down period to December 5,...more
On June 9, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published eleven new FAQs (FAQ 1058, FAQ 1059, FAQ 1060, FAQ 1061, FAQ 1062, FAQ 1063, FAQ 1064, FAQ 1065, FAQ 1066, FAQ 1067,...more
On June 2, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Russia-related General License (“GL”) 25B, GL 36, GL 37, and GL 38....more
On May 3, 2022, the U.S. Securities and Exchange Commission (“SEC”) staff issued a sample comment letter to alert public companies to potential disclosure obligations relating to the impact of Russia’s invasion of Ukraine and...more
Further measures have been taken against the Russian Federation by the United States and its allies since our last Russia-Related Sanctions Update. These recent measures include additional sanctions against the Russian...more