Belarus Sanctions

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On June 8, 2023, The Republic of Belarus (Sanctions) (EU Exit) (Amendment) Regulations 2023 (“Regulations”) were laid before parliament.  The Regulations significantly expand the UK’s package of sanctions targeting Belarus in response to the continued facilitation of Russia’s invasion of Ukraine by the Belarusian regime.  The new measures expand the criteria pursuant to which persons can be designated under the regime, target Belarusian imports used to fund the Lukashenko regime, crack down on Russia’s efforts to circumvent sanctions, and seek to limit the spread of propaganda by Belarusian organisations in the UK.  The new measures come into effect on June 9, 2023. 

In a press release announcing the measures, the Foreign, Commonwealth and Development Office stated that the Belarusian regime has facilitated Russia’s invasion of Ukraine by permitting the use of its territory and airspace by Russia to conduct missile and drone strikes against Ukraine, as well as providing significant training and logistical support to Russian forces.  Foreign Secretary, James Cleverly, also underscored that the UK’s “support for Ukraine will remain resolute for as long as it takes and the UK will not hesitate to introduce further measures against those who prop up Putin’s war.”…

Continue Reading UK Significantly Expands Sanctions Targeting Belarus

On March 14, 2023, the UK High Court issued a judgment in the first challenge to a UK sanctions listing under Section 38 of the Sanctions and Anti-Money Laundering Act 2018 (“SAMLA”).  The challenge was brought by LLC Synesis, a Belarusian technology company (“Synesis”) and followed an unsuccessful ministerial review of Synesis’ UK designation.  The High Court rejected the challenge on the grounds that the decision to maintain Synesis’ designation was reasonable and proportionate.  Mr. Justice Jay’s judgment addressed both the threshold for a UK listing and the standard of review the court is required to undertake when assessing a designation decision under Section 38 of SAMLA, points which will have broader relevance to future UK delisting cases.…

Continue Reading UK High Court Rejects First Challenge to a UK Sanctions Listing

On February 24, 2023, the US government announced a range of new export controls, sanctions, and tariffs to coincide with the first anniversary of Russia’s ongoing war against Ukraine. These actions by the US Department of Commerce, Bureau of Industry and Security (BIS), the US Department of the Treasury, Office of Foreign Assets Control (OFAC), the US Department of State, and the White House reflect the continued efforts of the US – in coordination with its allies – to impose costs on Russia for the war.

Each successive round of US export controls and sanctions presents new compliance challenges, against the backdrop of heightened enforcement risk resulting from aggressive, well-coordinated US government actions. US and non-US entities and individuals who engage in transactions related to Russia or Belarus should pay close attention to this complex and evolving regulatory framework. Additionally, entities and individuals exporting to Iran should take note of the expanded scope of the US Export Administration Regulations (EAR) under a new Iran Foreign Direct Product (FDP) Rule.…

Continue Reading US Imposes Additional Export Controls, Sanctions, and Tariffs targeting Russia, Belarus, and Iran On First Anniversary of Russia’s War Against Ukraine

On June 28, 2022, the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) and the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Joint Alert entitled “FinCEN and the U.S. Department of Commerce’s Bureau of Industry and Security Urge Increased Vigilance for Potential Russian and Belarusian Export Control Evasion Attempts” (“Joint Alert”).  The Joint Alert marks the first time FinCEN and BIS have collaborated on an alert of this nature and has important implications for both financial institutions and exporters/international trade parties.
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Continue Reading New Joint Alert Puts Export Compliance Focus on Financial Institutions

On 5 July 2022, the UK Government introduced a further round of financial, trade and transport sanctions against Belarus in response to its continuing support of Russia’s invasion of Ukraine.  The new sanctions measures were implemented pursuant to The Republic of Belarus (Sanctions) (EU Exit) (Amendment) Regulations 2022 (“Amended Regulations”), which extends a range of sanctions measures previously introduced against Russia to Belarus.
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Continue Reading UK Introduces Further Economic Sanctions Against Belarus Including Financial, Trade & Transport Sanctions

Between April 18 and May 2, 2022, the US government continued to ratchet up economic sanctions, export controls, and other restrictive trade measures targeting Russia.  Most significantly, on April 21, President Biden issued a Proclamation prohibiting “Russian-affiliated vessels” from entering US ports.  Otherwise, the US government has focused on utilizing its existing authorities to impose further costs on Russia.

Over the last two weeks of April, the US Treasury Department’s Office of Foreign Assets Control (OFAC) designated over 40 individuals and entities including Transkapitalbank (TKB), re-issued an expanded set of Ukraine- / Russia- Sanctions Regulations (URSR), and issued several new or revised general licenses, including one relating to the provision of assistance by nongovernmental organizations, and 8 Frequently Asked Questions (FAQs).

Separately, the Commerce Department’s Bureau of Industry and Security (BIS) continues to be focused on restricting the Russian aviation sector, issuing a temporary denial order (TDO) on the Russian cargo aircraft carrier, Aviastar, for operating aircraft on flights into and out of Russia without the BIS authorization required under the Export Administration Regulations (EAR), and providing weekly updates to its list of commercial and private aircraft operated in potential violation of the EAR.…

Continue Reading April 18 – May 2, 2022 Russian Sanctions Update

Since March 14, 2022, the United Kingdom has continued to introduce and announce new sanctions measures in response to Russia’s invasion of Ukraine.  The new UK measures include sanctions enforcement powers under the Economic Crime (Transparency and Enforcement) Act 2022, the designation of hundreds of individuals and entities under the UK’s Russia and Belarus sanctions regimes, the introduction of new general licences, the introduction and announcement of new sanctions measures, and the revision of various guidance documents.
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Continue Reading A Summary of New UK Sanctions Enforcement Powers and Further Ukraine-related UK Sanctions on Russia and Belarus

As of March 20, 2022, a new Executive Order (EO) prohibited certain imports, exports, the transfer of US dollar banknotes to Russia, and new investments involving certain sectors of the Russian economy.  The US Office of Foreign Assets Control (OFAC) also issued new General Licenses and Frequently Asked Question (FAQ) guidance. Additionally, the US Department of Commerce’s Bureau of Industry & Security (BIS) announced new regulations to control the export, reexport, and transfer (in country) of certain luxury goods to or within Russia and Belarus. BIS also identified numerous aircraft subject to US export controls jurisdiction that had flown to Russia without a license, and issued a reminder regarding the restrictions under General Prohibition 10 under the Export Administration Regulations (EAR) of servicing such aircraft.

Key points of these US sanctions developments and export controls are summarized below.

For a summary of US sanctions and export controls adopted between February 21 and March 8, 2022, see this Steptoe blog post.…

Continue Reading Update: New US Sanctions on Russia Target Certain Imports, Exports, Dollar Banknotes, and Investments

Since the adoption of the first sanctions package against Russia, the Council of the EU and the European Commission (“Commission”) have been working closely together to adopt increasingly severe sanctions to force President Putin back to the negotiating table in view of reaching a ceasefire. Coordination with allies has also been intense. Following our review of the first and second sanctions package, we analyze below the latest restrictive measures.

For more information on how these developments could impact your organization, contact a member of Steptoe’s Economic Sanctions team in Brussels.

For additional resources can be found on Steptoe’s “Sanctions against Russia: Implications for Business and International Trade” page.…

Continue Reading Update: EU Adopts Additional Sanctions Against Russia and Belarus over the War in Ukraine

The United States government has continued to impose numerous economic sanctions and export controls measures following Russia’s invasion of Ukraine.  On February 24, 2022, the US Commerce Department’s Bureau of Industry and Security (BIS) significantly expanded export controls applicable to Russia.  On February 25, 2022, the US Treasury Department’s Office of Foreign Assets Control (OFAC) added Russian President Vladimir Putin and others to the Specially Designated Nationals (SDN) List.  It also imposed significant economic sanctions measures targeting Russia’s financial system — including by imposing sanctions on Russia’s largest financial institutions and limiting the ability of certain Russian state-owned and private entities to raise capital.  Together, OFAC’s actions, which were taken pursuant to Executive Order (EO) 14024 following Russia’s invasion of Ukraine, are estimated to affect nearly 80 percent of all banking assets in Russia.

Finally, on February 26, 2022, the United States and European Union countries, together with the United Kingdom and Canada, announced an agreement to block certain Russian banks from access to SWIFT (with Japan also agreeing the following day), to impose sanctions on Russia’s Central Bank, and to limit the ability of certain Russian nationals connected to the Russian government to obtain citizenship in their countries. They further agreed to ensure effective transatlantic coordination in implementing sanctions, including by sanctioning additional Russian entities and persons, and by working together and with other governments around the world to identify and freeze sanctioned Russian assets.…

Continue Reading Biden Administration Imposes Sweeping Financial Sanctions, Export Controls after Russian Invasion of Ukraine