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
On June 19, 2017, Anthony Rapa was featured on Steptoe’s Cyberlaw Podcast to discuss the Senate’s adoption of tough Russia sanctions last week. While there has been a lot of emphasis on the fact that this bill would codify the Obama administration’s Russia sanctions into law, Anthony explains how tough the bill could be on … Continue Reading
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
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
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
The Russia Sanctions Review Act of 2017, as set out in companion House and Senate bills, seems to be gaining some traction. If enacted, it would codify into law the core portions of the US sanctions regime on Russia and provide for congressional review of any proposed sanctions relief by the President, not unlike the … Continue Reading
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
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
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
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 US economic sanctions programs targeting Iran, Cuba, Russia and other areas. Mr. Trump has said he … Continue Reading
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
On October 24, the EU announced that Liechtenstein, Norway, Montenegro, Albania, and Ukraine would renew sanctions against Russia in alignment with current EU policy. As we have previously discussed, the EU prolonged restrictive measures against Russia in September, after determining that the situation in Ukraine did not merit a change in sanctions policy. The asset … Continue Reading
Sunday’s presidential town hall debate was the second of three opportunities for candidates Donald Trump and Hillary Clinton to make their case to the American electorate. In addition to the discussion of personal and character issues, the candidates touched on a range of policy issues, including tax policy, financial services, energy, and international trade. The … Continue Reading
The Council of the European Union has decided to prolong by 6 months the application of EU restrictive measures targeting actions against Ukraine’s territorial integrity, sovereignty and independence. These sanctions consist of an asset freeze and a travel ban against 146 persons and 37 entities. They have been extended until 15 March 2017. The measures … Continue Reading
Tomorrow, September 7, the US Department of Commerce, Bureau of Industry and Security (BIS) will issue a final rule adding 81 entities to the BIS Entity List (15 C.F.R. Part 744, Supplement No. 4) under the Export Administration Regulations (EAR). BIS is designating the companies, which are based in Russia, the Crimea region of Ukraine, India, … Continue Reading
Yesterday, the US Treasury Department, Office of Foreign Assets Control (OFAC) designated several new Russian and Ukrainian Specially Designated Nationals (SDNs) and Sectoral Sanctions Identification (SSI) List entities under the Ukraine-Related Sanctions Regulations (31 C.F.R. Part 589). The designations are explained in a press release and set out in detail in a web notice. The … Continue Reading
The EU has extended, today, economic sanctions targeting specific sectors of the Russian economy to 31 January 2017. The extension is set out in Council Decision (CFSP) 2016/1071. The sanctions concern the financial, energy and defence sectors, as well as dual-use goods, and have been extended because the Council has assessed that the Minsk agreements … Continue Reading
Yesterday, the French Senate voted 302-16 to “gradually and partially” lift sanctions on Russia, despite opposition from the Hollande government. While this vote has no legal effect, it was a strong showing of political opposition in France to the continuing EU sanctions. The US and EU have largely remained aligned on their policy that Russia … Continue Reading
US and EU regulators have warned banks not to participate in a proposed $3 billion, 10-year Russia Eurobond offering, even if participation will not technically violate US sanctions laws targeting Russia based on its annexation of Crimea and destabilization of eastern Ukraine. Russia reportedly invited European and Chinese banks to bid on the proposed offering, … Continue Reading
On December 22, the US Treasury Department, Office of Foreign Assets Control (OFAC) designated 34 individuals and entities for sanctions under the Ukraine-Related Sanctions Regulations. First, OFAC designated new Specially Designated Nationals (SDNs) based on their being owned by Gennady Timchenko, Arkady Rotenberg, Boris Rotenberg, Kalashnikov Concern, or Izhevsky Mekhanichesky Zavod JSC, all of whom were previously designated as SDNs; … Continue Reading
On September 2, 2015, the US Government announced the imposition of measures including the following against Rosoboronexport (ROE) (Russia) and any successor, sub-unit, or subsidiary thereof: “No department or agency of the United States Government may procure or enter into any contract for the procurement of any goods, technology, or services from [Rosoboronexport (ROE) (Russia) … Continue Reading
Join us on Tuesday, December 15 for this complimentary webinar discussing economic sanctions, export control, and related developments over the past year. Featured panelists include Steptoe International Compliance Blog contributors Alex Baj, Jack Hayes, Stephen Heifetz, Andy Irwin, Anthony Rapa, Meredith Rathbone, and moderator Ed Krauland. Date: Tuesday, December 15, 2015 Time: 12:00 p.m. – 1:30 … Continue Reading
On August 7, the US Department of Commerce, Bureau of Industry and Security (BIS) designated the Yuzhno-Kirinskoye Field, a Russian oil and gas field located in the Sea of Okhotsk and owned by Gazprom, on its Entity List. Consequently, a license will be required to export, reexport, or transfer (in-country) to the field any item … Continue Reading
On July 30, OFAC designated VEB and Rosneft subsidiaries on the SSI List and added Russian and Ukrainian persons to the SDN List. OFAC also issued an advisory regarding evasion of sanctions against Crimea. OFAC’s actions reflect a continuing commitment by US authorities to enforcement of existing sanctions related to the situation in Ukraine. For … Continue Reading
