Between March 24 and April 1, 2022, the US Treasury Department’s Office of Foreign Assets Control (OFAC) designated over 400 Russian elites, Duma members, and defense companies as Specially Designated Nationals (SDNs) pursuant to Executive Order (EO). 14024. OFAC also published four new, limited General Licenses regarding certain humanitarian, import-related, diplomatic, and journalistic activities, added one new FAQ, and published a determination for EO 14024. Separately, the White House has indicated that the United States is seriously considering imposing secondary sanctions against companies engaged in evasive activities with Russia or in business that otherwise undermines sanctions.

Additionally, on April 1, the Commerce Department’s Bureau of Industry and Security (BIS) added 120 entities in Russia and Belarus to the Entity List.

For a summary of prior US sanctions and export controls related to Russia adopted since February 21, 2022, please see our Steptoe blog posts from March 21, March 8, and February 27.

Continue Reading A Summary of The Latest US Sanctions on Russia

On September 21, 2021, the US Department of the Treasury’s Office of Foreign Asset Control (OFAC) issued an updated advisory on the sanctions risks of facilitating ransomware payments.  OFAC issued a prior version of its advisory on October 1, 2020. In the months since, attacks have continued and target entities in the United States, including many in sensitive industries, generating increased concern over the scale of the problem. OFAC’s updated advisory is part of the Biden administration’s ongoing efforts to address the national security and economic risks posed by such attacks. The updated advisory emphasizes that OFAC “strongly discourages” victims from making ransom payments and reemphasizes the sanctions risks of doing so, but also seeks to provide victims with greater clarity about the steps that can be taken to reduce the likelihood of a public enforcement response if a company inadvertently makes or facilitates ransom payments that may have a sanctions nexus.

Continue Reading OFAC Issues Revised Ransomware Advisory