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
Russian Oil Price Cap -
The G7 has agreed to a U.S.-led coalition to impose a price cap on Russian oil exports to stem Russian profits from sales of oil to fuel its war efforts against Ukraine. On September 2, 2022, the...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 28, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued five new General Licenses (“GL”) (GL 39, GL 40, GL 41, GL 42, and GL 43), released a new determination prohibiting gold...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 May 5, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License No. 31 (“GL 31”), which makes clear that U.S. Persons may continue to act in the Russian Federation to...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 11, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) updated three FAQs (FAQ 1034, FAQ 1035, and FAQ 1038). Specifically, OFAC amended its guidance on the meaning of the terms...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
Executive Order 14071 “Prohibiting New Investment in and Certain Services to the Russian Federation in Response to continued Russian Federation Aggression” - April 6, 2022 -
Executive Order 14071 (“EO 14071”) blocks any...more
The United States, primarily through Presidential action under the statutory authority of the International Emergency Economic Powers Act (“IEEPA”), has empowered the U.S. Department of the Treasury and its Office of Foreign...more
2/24/2022
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