Archives: Russia/Ukraine Sanctions

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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 US 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

Non-Member States Align with EU on Russia Sanctions Extension

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

How the 2016 Election Will Impact Public Policy Developments

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

EU Prolongs Sanctions Over Actions Against Ukraine’s Territorial Integrity

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

BIS Adds Russian Companies to Entity List

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

New Russia Sanctions Designations

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

EU Extends Russia Sanctions Through January 2017

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

French Senate Overwhelmingly Votes to Roll Back Russia Sanctions

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 Dissuade Banks from Participating in Russian Bond Offering

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

BIS and OFAC Make New Russia Designations, BIS Issues Russia Guidance

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

Sanctions Partially Removed on Russian Entity to Allow Maintenance Subcontracts for Mi-17 Helicopters used in USG Programs

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

Upcoming Webcast: 2015 Developments Regarding Economic Sanctions and Export Controls

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

BIS Moves into Uncharted Waters with Its Designation of the Yuzhno-Kirinskoye Oil/Gas Field

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

OFAC Adds Rosneft and VEB Subsidiaries to SSI List, Designates Russian SDNs, Advises on Evasion

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