Archives: Russia/Ukraine Sanctions

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More Sanctions Ahead After Treasury’s Reports to Congress on Russian Oligarchs, Defense/Intel Sanctions?

The Treasury Department late last night issued several reports to Congress pursuant to mandates in the Countering America’s Adversaries Through Sanctions Act (CAATSA), including under CAATSA Sections 241 (Report on Senior Foreign Political Figures and Oligarchs in the Russian Federation) and 242 (Report on Effects of Expanding Sanctions to Include Sovereign Debt and Derivative Products). … Continue Reading

Russia Sanctions: Amended OFAC Directive 4 Effective Today

Today is the effective date of the expanded sanctions set out in Directive 4 under the U.S. Russia sanctions program, as amended by the U.S. Department of Treasury, Office of Foreign Assets Control (OFAC) on October 31, 2017.  The amendment implemented Section 223 of the Countering America’s Adversaries Through Sanctions Act (CAATSA), signed into law … Continue Reading

More on the Russian Oligarch Report

As indicated in recent media reports, for example from Bloomberg and The Wall Street Journal, many are closely watching developments related to the “Russian oligarch” report due from the Trump Administration next week under Section 241 of the Countering America’s Adversaries Through Sanctions Act.  Under Section 241, the Secretary of the Treasury (in consultation with the … Continue Reading

New Guidance Points to Potentially Aggressive Application of Secondary Sanctions on Russia

The US Departments of State (State) and the Treasury (Treasury) have, in recent weeks, issued implementation guidance on the new secondary sanctions on Russia in the Countering America’s Adversaries Through Sanctions Act (CAATSA), which became law on August 2, 2017.  For a  general discussion of CAATSA, please see our previous advisory.  This advisory addresses each of … Continue Reading

Russian Sanctions Update: OFAC Amends Directive 4 and Updates FAQ Guidance

On October 31, 2017, the Office of Foreign Assets Control (OFAC) took a number of actions to implement the Countering Russian Influence in Europe and Eurasia Act (CRIEEA) (also known as the Countering America’s Adversaries Through Sanctions Act (CAATSA), a larger sanctions statute of which CRIEEA was a part).  As part of this, OFAC amended Directive … Continue Reading

Economic Sanctions Webinar

On Wednesday, November 15 at 12:00 PM EST, Anthony Rapa will be presenting “Recent Developments in Economic Sanctions: Russia, Iran, Venezuela, North Korea, and Cuba,” a webinar hosted by Federal Publications.  As described on the Federal Publications website: From “decertifying” the Iran deal to disputes with “Rocket Man,” the economic sanctions world has seen dizzying … Continue Reading

State Department Allows Certain Civilian Trade to Continue with Russia’s Defense Sector

On October 27, 2017, the US Department of State, pursuant to Section 231 of the Countering America’s Adversaries Through Sanctions Act (CAATSA), published the list of entities that are part of, or operate for or on behalf of, the Russian defense or intelligence sectors, as well as Guidance that sets out indicators of how the … Continue Reading

OFAC Shortens New Debt Maturity Periods under Russian Financial and Energy Sectoral Sanctions

OFAC today revised its Ukraine/Russia-related sectoral sanctions directives prohibiting US person dealings in new debt or new equity of listed Russian financial institutions and new debt of listed Russian energy companies (in both cases, these prohibitions continue to apply to the “interests in property” of the listed entities, meaning any entity 50% or more owned … Continue Reading

A Detailed Look at the Countering America’s Adversaries Through Sanctions Act

President Trump signed the Countering America’s Adversaries Through Sanctions Act into law on August 2, 2017, targeting Russia, North Korea, and Iran.  The law serves as a forceful, bipartisan statement that the US Congress continues to view robust economic sanctions as a foundation of US foreign policy, in which Congress will play a leading role … Continue Reading

UPDATE: Congress Passes Sweeping Iran, Russia, and North Korea Sanctions Legislation

On July 27, the Senate passed 98-2 the Countering America’s Adversaries Through Sanctions Act (HR 3364), which previously passed the House 419-3 on July 25, setting up  a showdown with President Trump. This bill is an omnibus of three separate sanctions measures: the Countering Iran’s Destabilizing Activities Act (“CIDAA”), the Countering Russian Influence in Europe … Continue Reading

Sanctions Round-Up

Sanctions, sanctions, and more sanctions– everyone’s favorite tool of foreign policy sure has been making a lot of news lately.  Here’s a round-up of the latest sanctions analysis here at the International Compliance Blog: Russia: Peter Jeydel summarized the Russia sanctions bill that the Senate passed on June 14, while Alexis Early assessed the bill’s prospect for passage … Continue Reading

Back to the Future on “Extraterritorial” Sanctions on Russian Pipelines?

Earlier this month, after the Senate overwhelmingly passed a bill that would authorize (and in some cases mandate) sanctions on foreign energy firms that participated in certain Russian energy projects, the Governments of Germany and Austria issued a joint statement that they “cannot accept a threat of extraterritorial sanctions, illegal under international laws, against European … Continue Reading

What Can We Say About The Trump Administration’s First Russia Sanctions?

The Treasury Department’s Office of Foreign Assets Control (OFAC) today designated 38 individuals and entities in order to “reinforce[] existing sanctions on Russia.”  This announcement came while President Trump was meeting the President of Ukraine in the White House.  These were the first new sanctions under the Trump Administration related to the conflict in Ukraine … Continue Reading

Congress Flexes Sanctions Muscles: Bills Target Iran, Russia, and Others

This month, Congress is considering an array of new sanctions-related legislation, and, in recent days, bipartisan support has grown for a bill that would potentially direct significant measures against Russia and Iran. Congress has also debated bills proposing new sanctions against North Korea, Hamas, Hezbollah, and both chambers have put forth multiple bills that would … Continue Reading

Senate Moving Forward with Strong Russia Sanctions Bill Targeting Energy and Financial Services

Last night, a key group of bipartisan senators reached agreement on, and introduced, a Russia sanctions amendment to a broader sanctions bill focused on Iran, which could be voted on as early as this week.  It is called the Countering Russian Influence in Europe and Eurasia Act of 2017 (CRIEEA).  The CRIEEA does not adopt … Continue Reading

OFAC Issues General License Authorizing Certain Dealings with FSB Related to Encryption Import Licensing

The US Treasury Department’s Office of Foreign Assets Control (OFAC) issued a General License today authorizing certain transactions with the Russian Federal Security Service (known as “FSB”) related to seeking licenses, notifications, and other authorizations with the FSB for the importation, distribution, or use of information technology products in the Russian Federation.  The General License … Continue Reading

Groundbreaking Russia Sanctions Bill Introduced in the Senate

A bipartisan group of US Senators introduced a bill on January 11, 2017 – the Countering Russian Hostilities Act of 2017 – that would impose unprecedented sanctions on Russia and persons and entities conducting certain types of business involving Russia.  This bill would codify into law most of the existing sanctions targeting Russia, making it … Continue Reading

New US Cyber Sanctions on Russia

Obama Expands Cyber Sanctions to Cover Election Hacking, Then Uses it to Sanction Russian Intelligence Agencies and Others On December 29, 2016, the President amended Executive Order 13964, which was originally issued in April 2015, to explicitly authorize sanctions on those found to be “tampering with, altering, or causing a misappropriation of information with the … Continue Reading

What to Expect for Economic Sanctions Under President Trump?

President-elect Trump has made bold and surprising pronouncements about what he may do after January 20 in the field of international affairs, and these foreign policy choices are likely to have a significant impact on the future course of U.S. economic sanctions programs targeting Iran, Cuba, Russia and other areas. Mr. Trump has said he … Continue Reading

What a Trump Administration Could Mean for International Regulatory Compliance

After the November 8, 2016 elections, Washington is preparing for a new Congress and the transition of power from eight years of the Democratic Obama administration to the Republican administration of President-elect Donald Trump.  As the incoming president builds his transition team and sets out his policy priorities, Steptoe will examine what these changes may … Continue Reading
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