Heightened US sanctions and export restrictions targeting Russia

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United States Publication March 2022

The US sanctions space is very active and changes are made frequently. This publication has been updated to reflect the most recent changes and is current as of April 25, 2022.


On February 21, 2022, the US government began taking a series of actions in response to Russia's announcement that it would recognize as "independent" two regions of Ukraine. As of the date of this publication, these actions include:

  • A new Executive Order issued by US President Joseph Biden on February 21, 2022 (EO 14065), which expands the comprehensive sanctions relating to Ukraine to now include the so-called Donetsk People's Republic (DNR) and Luhansk People's Republic (LNR) in addition to Crimea, resulting in severe restrictions on economic activity with these regions, including regulations to implement EO 14065.1
  • A joint decision between the United States, European Commission, France, Germany, Italy, the United Kingdom and Canada to remove several Russian banks from SWIFT, the high-security network supporting transactions and payments in the international financial system.
  • Blocking sanctions on several entities and individuals, including several major Russian financial institutions and their subsidiaries; Russian President Vladimir Putin, and several prominent Russians and their family members; certain entities that manage Russia's key sovereign wealth funds and the CEO of one of those entities; the company building the Nord Stream 2 pipeline and its CEO; and several Belarusian individuals and entities across Belarus' defense and financial institution sectors, effectively restricting their ability to do business in the United States and curtailing their access to the US financial system.
  • Correspondent and payable-through account and payment processing prohibitions on the largest Russian financial institution and its subsidiaries, restricting their ability to process payments through the US financial system.
  • New prohibitions related to transactions involving Russia's central bank designed to immobilize any Russian central bank assets held in the United States or by US persons.
  • New prohibitions related to new debt and equity of major Russian state-owned enterprises and large privately owned financial institutions.
  • Expanded sovereign debt prohibitions to restrict US individuals and financial institutions from participation in secondary markets for ruble- or non-ruble-denominated bonds issued by certain Russian sovereign entities.
  • A determination that any institution in the financial services sector of Russia can be a target for further sanctions.
  • New and expanded US export controls primarily targeting Russia's defense, aerospace, and maritime sectors, including restrictions on exports of sensitive US items and non-US items produced using US equipment, software, and blueprints—such as semiconductors, telecommunication, encryption security, lasers, sensors, navigation avionics and maritime technologies—and stringent controls on several Russian military end users that are now subject to restrictions on exports of all US items.
  • Two new executive orders (EO 14066 and EO 14068) further restricting connections between the Russian and US economies, including prohibitions on a wide range of Russian-origin imports, Russian-bound exports, new investments in the Russian economy, and financing activities.
  • A determination that any person in the aerospace, electronics, and marine sectors of the Russian economy can be a target for blocking sanctions.
  • Multilateral and multi-departmental task forces targeting individuals and corporations seeking to evade or undermine US sanctions.
  • A new executive order (EO 14071) prohibiting any new investment in Russia and the export, reexport, sale, or supply, of any designated services to persons in Russia.

As detailed below, these actions, in addition to those taken by the United Kingdom, the European Union and other US allies and partners, have potentially significant implications for US and non-US companies that have business activities touching Russia and Ukraine. Given the rapidly evolving situation in Ukraine, companies should be prepared for likely forthcoming additional sanctions, and take steps to mitigate the associated risks. 

Please note, this document is not intended to be an exhaustive summary of all the nuances of the new sanctions and export restrictions, nor to provide advice on specific transactions or activities, and as the Ukraine situation continues to develop, the information provided herein may be subject to change.

EO 14065

EO 14065 is similar in style to EO 13685 of December 19, 2014, issued by President Barack Obama in response to Russia's annexation of Crimea. It prohibits transactions by US persons or otherwise within the United States involving the following activities:

  • New investment in the so-called DNR or LNR regions of Ukraine by a US person, wherever located;
  • The importation into the United States, directly or indirectly, of any goods, services, or technology from the so-called DNR or LNR regions of Ukraine;
  • The exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a US person, wherever located, of any goods, services, or technology to the so-called DNR or LNR regions of Ukraine; and
  • Any approval, financing, facilitation, or guarantee by a US person, wherever located, of a transaction by a non-US person where the transaction by that non-US person would be covered by these prohibitions if performed by a US person or within the United States.

EO 14065 also blocks all property and interests in property that are in the United States or that come within US person possession or control of any person determined by the Secretary of the Treasury in consultation with the Secretary of State:

  • To operate or have operated since the date of the order in the so-called DNR or LNR regions of Ukraine;
  • To be or have been since February 21, 2022, a leader, official, senior executive officer, or member of the board of directors of an entity operating in the so-called DNR or LNR regions of Ukraine;
  • To be owned or controlled by, or to have acted or purported to act for or on behalf of, directly or indirectly, any person whose property and interests in property are blocked pursuant to this order; or,
  • To have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, any person whose property and interests in property are blocked pursuant to this order.

The US Department of the Treasury's Office of Foreign Assets Control (OFAC) concurrently issued several General Licenses (GLs) to ensure that activity that would otherwise be prohibited by the sanctions can continue in these regions. The GLs authorize:

  • Agricultural commodities, medicine, medical devices, replacement parts and components, software updates, and COVID-19-related items and supplies;2
  • Telecommunications and mail transactions;3
  • Certain official business of specified international humanitarian organizations;4
  • Certain non-commercial personal remittances and related operation of financial accounts;5
  • Exports of certain services and software incident to internet-based communications.6
  • Certain transactions in support of nongovernmental organizations' activities, including humanitarian support, democracy building, education, non-commercial development projects, and environmental and natural resource protection in the DNR and LNR regions;7
  • Civil maritime service transactions with residents in the DNR and LNR regions; and8
  • Journalistic activities and establishment of news bureaus in the DNR and LNR regions of Ukraine.9

New export and import prohibitions pursuant to EO 14066 and EO 14068

Within the span of one week, President Biden signed two new executive orders placing prohibitions on a range of Russian-origin imports and Russian-bound exports, as well as new investments and financing activities benefitting the Russian economy.

On March 8, 2022, President Biden signed EO 14066 to prohibit imports of Russian oil, liquefied natural gas, coal, and related products into the United States and prohibiting US persons from engaging in any new investment in the energy sector of the Russian Federation. These restrictions specifically target Russian-origin products, and do not affect those simply passing through the Russian Federation.

Building upon EO 14066, EO 14068 sets forth a wider set of restrictions, including prohibitions on:

  • Imports of Russian fish, seafood, alcoholic beverages, non-industrial diamonds, and other Russian origin products as designated by the Secretary of the Treasury; 
  • The exportation, reexportation, sale, or supply, directly or indirectly, from the United States or by a US person, wherever located, of luxury goods to any person located in the Russian Federation; 
  • New investment, by a US person, wherever located, in any sector of the Russian economy, as may be determined by the Secretary of the Treasury; 
  • The exportation, reexportation, sale, or supply, directly or indirectly, from the United States or a US person, wherever located, of US dollar-denominated banknotes to the Government of the Russian Federation or any person located in the Russian Federation; and 
  • Any approval, financing, facilitation, or guarantee by a US person, wherever located, of a transaction by a foreign person where such transaction would be prohibited if performed by a US person or within the United States.

This EO establishes the legal authority for future investment restrictions in any sector of the Russian economy, as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State, by a US person. EO 14068 is just the first of the United States's steps to implement coordinated measures against Russia by the United States, EU, and the G7. These measures are intended "to hold Putin accountable for his continued assault on Ukraine and further isolate Russia from the global financial system."10

OFAC concurrently issued GLs authorizing:

  • Transactions ordinarily incident and necessary to the importation into the United States of fish, seafood, and preparations thereof of Russian-origin pursuant to written contracts or written agreements entered into prior to March 11, 2022 through 12:01 a.m. EDT, June 23, 2022;11
  • Transactions ordinarily incident and necessary to the transfer of US dollar-denominated banknote noncommercial, personal remittances from: (i) the United States or a US person, wherever located, to an individual located in the Russian Federation; or (ii) a US person who is an individual located in the Russian Federation;12 and
  • Transactions by US persons located in the Russian Federation for their personal maintenance within the Russian Federation, including payment of housing expenses, acquisition of goods or services for personal use, payment of taxes or fees, and purchase or receipt of permits, licenses, or public utility services.13

On March 11, 2022, President Biden also announced that the US also would:

  • Revoke Russia's Most-Favored Nation Status, working closely with Congress to deny Russia the benefits of its WTO membership and ensure that Russian imports do not receive most favored nation (MFN) treatment in our economy, together with similar actions by the G7;
  • Work with G7 Leaders to deny borrowing privileges at multilateral financial institutions;
  • Impose full blocking sanctions on additional Russian elites and their family members, including executives of sanctioned banks, and Duma members who sponsored legislation to recognize the so-called "Donetsk People's Republic" and "Luhansk People's Republic," cutting them off from the US financial system, freezing any assets they hold in the United States, and blocking their travel to the United States; and
  • Issue new Treasury Department guidance to thwart sanctions evasion, including through virtual currency, underscoring that Treasury's actions against Russia require all US persons to comply with sanctions regulations regardless of whether a transaction is denominated in traditional fiat currency or virtual currency.

On April 11, 2022, President Biden signed two pieces of legislation. First, H.R. 6968, the "Ending Importation of Russian Oil Act," which statutorily prohibits the importation of energy products from Russia. Second, H.R. 1708, the "Suspending Normal Trade Relations with Russia and Belarus Act," a bipartisan effort to revoke MFN treatment from Russia and Belarus under the US Harmonized Tariff Schedule. With this revocation of status, the ad valorem tax on Russian and Belarusian imports rises from approximately 4 percent to approximately 30 percent. Additionally, President Biden now has the authority to impose tariffs higher than this non-MFN rate until January 1, 2024. President Biden also has the authority to temporarily or permanently restore MFN treatment if aggression in Ukraine ceases and other conditions are met. Additionally, the US Trade Representative is instructed to seek Russia's suspension from the WTO.

Blocking sanctions pursuant to EO 14024 and EO 14039

OFAC has designated, pursuant to EO 14024 (issued on April 15, 2021), several Russian entities and individuals in an effort to curb their access to the US financial system and markets, including the following: 

  • On February 22, 2022, two major Russian state-owned financial institutions (Vnesheconombank and Promsvyazbank), along with 42 of their subsidiaries across a wide range of businesses; five vessels owned by one of the designated subsidiaries; and five Russian "elites and their family members" determined by the US to be directly benefitting from relationships with the Kremlin and President Putin;14
  • On February 24, 2022, four major Russian state-owned financial institutions (VTB Bank, Otkritie, Sovcombank, and Novikombank), one of which (VTB) OFAC described as "one of the largest financial institutions Treasury has ever blocked,"15 along with 54 of their subsidiaries, as well as seven Russian "elites and their family members" determined by the US to be benefitting from relationships with the Kremlin and funding President Putin's invasion of Ukraine;16
  • On February 24, 2022, 24 Belarusian individuals and entities across Belarus' defense and financial sectors;17
  • On February 25, 2022, President Putin and Russian Minister of Foreign Affairs Sergei Lavrov,18 as well as 11 additional members of Russia's Security Council determined by the US to be leaders, officials, senior executive officers, or members of the board of directors of the Russian Government;
  • On March 11, 2022, Yuri Kovalchuk, several executives of sanctioned Russian banks, and Duma members who sponsored legislation to recognize the so-called "Donetsk People's Republic" and "Luhansk People's Republic";19
  • On March 24, 2022, Sberbank CEO Herman Gref, dozens of Russian defense companies, and 328 members of the Russian State Duma;20
  • On April 6, 2022, former President and Prime Minister Dmitry Medvedev, Prime Minister Mikhail Mishustin, President Putin's daughters, Foreign Minister Lavrov's wife and daughter, Sberbank and 42 of its subsidiaries, Alfa-Bank and six of its subsidiaries as well as five of its vessels, and the remaining members of Russia's Security Council;21 and
  • On April 7, 2022, Russian state-owned diamond mining company Alrosa as well as Russian state-owned warship manufacturer United Shipbuilding Corporation.22

In addition, on February 23, 2022, OFAC designated the company involved in building the Nord Stream 2 pipeline and its CEO, pursuant to EO 14039 of August 20, 2021, implementing the Protecting Europe's Energy Security Act (PEESA) targeting Russian energy export pipelines.

On March 31, 2022, US Secretary of the Treasury Janet Yellen released a determination that blocking sanctions under EO 14024 may be applied to persons in the aerospace, electronics, and marine sectors of the Russian Federation economy. 

The above-mentioned entities and individuals have been added to OFAC's Specially Designated Nationals and Blocked Persons (SDN) List. As a result of these blocking actions, all property and interests in property of the designated persons that are in the United States or in the possession or control of US persons are blocked and must be reported to OFAC. In addition, any entities that are owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked. Unless authorized or otherwise exempt, all transactions by US persons or within (or transiting) the United States that involve any property or interests in property of blocked persons are generally prohibited. The prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any blocked person, or the receipt of any contribution or provision of funds, goods, or services from any such person. 

Correspondent and payable-through account sanctions pursuant to EO 14024

On February 24, 2022, OFAC imposed correspondent and payable-through account sanctions on Sberbank, which it characterized as "the largest financial institution in Russia," along with 25 of its non-US financial institution subsidiaries.23 OFAC is requiring all US financial institutions to close, within 30 days, any correspondent or payable-through accounts of this financial institution and to reject any future transactions involving that financial institution or its non-US financial institution subsidiaries. As a result of this action, payments that the targeted financial institution attempts to process in US dollars for its clients will be disrupted and rejected once the payment hits a US financial institution. 

To implement these sanctions, OFAC issued Directive 2 under EO 14024 (the Russia-related CAPTA Directive).24 This directive prohibits US financial institutions from:

  • Opening or maintaining of a correspondent account or payable-through account for or on behalf of any entity determined to be subject to the prohibitions of the Russia-related CAPTA Directive, or their property or interests in property; and
  • Processing of transactions involving any such entities determined to be subject to the Russia-related CAPTA Directive, or their property or interests in property. 

US financial institutions are required to reject such transactions unless exempt or authorized by OFAC. The prohibitions of the Russia-related CAPTA Directive apply with respect to any currency.25 The entities determined to be subject to the Russia-related CAPTA Directive have been added to OFAC's List of Foreign Financial Institutions Subject to Correspondent Account or Payable-Through Account Sanctions (CAPTA List), a reference tool that provides notice of OFAC actions with respect to non-US financial institutions for which the opening or maintaining of a correspondent account or a payable-through account in the United States is prohibited or subject to one or more strict conditions.26 All non-US financial institutions that are owned 50 percent or more, directly or indirectly, by the targeted Russian financial institution are covered by the prohibitions of the Russia-related CAPTA Directive, even if not identified on OFAC's CAPTA List. 

The prohibitions of the Russia-related CAPTA Directive take effect beginning at 12:01 a.m. EDT on March 26, 2022. All other activities with, or involving property or interests in property of, non-US financial institutions determined to be subject to the prohibitions of the CAPTA Directive are permitted, unless otherwise prohibited.

New prohibitions relating to transactions with Russian Central Bank

On February 28, 2022, OFAC issued new Directive 4 under EO 14024, pursuant to which US persons are prohibited from engaging in transactions with the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation.27 Directive 4 prohibits any transaction by US persons involving these three entities, including any transfer of assets to such entities or any foreign exchange transaction for or on behalf of such entities. All other activities with these entities, or involving their property or interests in property are permitted, provided they are not otherwise prohibited by law, EO 14024, or other OFAC sanctions programs. Contemporaneously with the issuance of the directive, OFAC issued a general license authorizing certain energy-related transactions with the Central Bank of the Russian Federation.28

New debt and equity prohibitions against major state-owned and private entities

On February 24, 2022, OFAC expanded Russia-related debt and equity restrictions to cover additional key aspects of the Russian economy. To implement this action, OFAC issued Directive 3 under EO 14024 (the Russia-related Entities Directive)29 to prohibit transactions and dealings by US persons or within the United States in new debt of longer than 14 days maturity and new equity of Russian state-owned enterprises, entities that operate in the Russian financial services sector, and other entities determined to be subject to the prohibitions of the directive. These 13 major firms, which are listed in an annex to the directive, include six of Russia's largest financial institutions, such as Gazprombank, Sberbank, Promsvyaz Bank, Russian Agricultural Bank, Sovcomflot and Alfa-Bank. These entities are now significantly restricted from raising funds through the US market.

More specifically, Directive 3 prohibits the following activities by US persons or within the United States, unless licensed or otherwise authorized:

  • For new debt or new equity of entities listed in Annex 1, or their property or interests in property, all transactions in, provision of financing for, and other dealings in new debt of longer than 14 days maturity or new equity where such new debt or new equity is issued on or after 12:01 a.m. EDT on March 26, 2022; and
  • For new debt or new equity of entities otherwise determined to be subject to the prohibitions of this Directive, or their property or interests in property, all transactions in, provision of financing for, and other dealings in new debt of longer than 14 days maturity or new equity where such new debt or new equity is issued on or after 12:01 a.m. EDT on the date that is 30 days after the date of such determination.

The term "debt" includes bonds, loans, extensions of credit, loan guarantees, letters of credit, drafts, banker's acceptances, discount notes or bills or commercial paper. The term "equity" includes stocks, share issuances, depositary receipts, or any other evidence of title or ownership.30 These prohibitions apply to all new debt with a maturity of greater than 14 days and new equity irrespective of currency denomination.31

Directive 3 does not prohibit US persons from engaging in dealings relating to debt or equity issued before the relevant sanctions effective date by subject entities "so long as the terms of such debt (including the repayment period, the interest rate, and the amount) were contractually agreed to before the relevant sanctions effective date described in the Russia-related Entities Directive and are not modified on or after the relevant sanctions effective date."32

The prohibitions apply to entities owned 50 percent or more by one or more of the sanctioned persons.33 All other activities with entities determined to be subject to the prohibitions of this directive, or involving their property or interests in property, are permitted, provided that such activities are not otherwise prohibited by law, EO 14024, or any other sanctions program implemented by OFAC. 

A listing of entities determined to be subject to the prohibitions of this directive, including the entities listed in the annex to the directive, can be found on OFAC's Non-SDN Menu-Based Sanctions (NS-MBS) List. Some entities determined to be subject to the prohibitions of the Russia-related Entities Directive also may be subject to additional prohibitions under other sanctions authorities, such as additional directives under EO 14024 or EO 13662. Each directive operates independently of the others; for example, if a transaction involves a person subject to two separate directives, a US person engaging in that transaction must comply with both directives.34

Expanded sovereign debt restrictions pursuant to EO 14024 and newly issued Directive 1A

On February 22, 2022, the US expanded prohibitions on Russian sovereign debt designed to "den[y] Russia access to key US markets and investors."35 More specifically, pursuant to EO 14024, OFAC issued Directive 1A (the Russia-related Sovereign Debt Directive),36 amending and superseding Directive 1. Directive 1 imposed prohibitions on US persons' participation in the primary market for ruble or non-ruble denominated bonds issued by, or the lending of ruble or no-ruble denominated funds to, certain Russian sovereign entities. Directive 1A extends those prohibitions to also cover, as of March 1, 2022, US persons' participation in the secondary market for ruble or non-ruble denominated bonds issued by these entities after March 1, 2022.37 These entities have now been added to OFAC's NS-MBS List.

OFAC's 50 Percent Rule does not apply to Directive 1A. Under FAQ # 891, the prohibitions of the Russia-related Sovereign Debt Directive apply only to bonds issued by, or loans made to, the enumerated Russian sovereign entities, and do not apply to the property or interests in property of those entities.38

Financial sector determination pursuant to EO 14024

On February 22, 2022, the Secretary of the Treasury, in consultation with the Secretary of State, determined that section 1(a)(i) of EO 14024, which authorizes the imposition of sanctions on persons determined to operate in certain Russian sectors, applies to the financial services sector of the Russian economy. When EO 14024 was issued on April 15, 2021, the technology sector and defense and related materiel sector of the Russian economy were identified. As OFAC explained, "A sector determination pursuant to EO 14024 exposes persons who operate or have operated in an identified sector to sanctions risk; however, a sector determination does not automatically impose sanctions on all persons who operate or have operated in the sector." Only persons who are determined, pursuant to EO 14024, to operate or have operated in the identified sectors are subject to sanctions.

Persons sanctioned pursuant to EO 14024 for operating or having operated in an identified sector are added to one or more OFAC sanctions lists based on the type of sanction, including the SDN List, the CAPTA List and the NS-MBS List. 

Additional general licenses

As noted above, OFAC has issued certain general licenses (GLs) authorizing otherwise prohibited conduct in an effort to minimize unintended consequences. In addition to those mentioned above, with respect to conduct otherwise prohibited by EO 14024, OFAC has issued GLs authorizing:

  • Certain transactions related to the servicing of certain bonds issued before March 1, 2022;39
  • Certain official business of specified international organizations and entities;40
  • Transactions related to exports or reexports of agricultural commodities, medicine, medical devices, replacement parts and components or software updates, the COVID-19 pandemic;41
  • Overflight payments, emergency landings, and air ambulance services;42
  • Transactions involving certain enumerated entities (and entities in which they own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest) that are "related to energy"43 through 12:01 a.m. EDT, June 24, 2022;44
  • Transactions related to dealings in debt or equity of certain enumerated entities (VEB, Otkritie, Sovcombank, Sberbank or VTB) and entities in which they own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest) issued prior to February 24, 2022 through 12:01 a.m. EDT, May 25, 2022, provided that any divestment or transfer of, or facilitation of divestment or transfer of, covered debt or equity must be to a non-US person;45
  • Transactions related to the facilitating, clearing, or settling of trades for debt or equity involving VEB, Otkritie, Sovcombank, Sberbank, or VTB, provided such trades were placed prior to 4:00 p.m. EST, February 24, 2022, until 12:01 a.m. EDT, May 25, 2022;46
  • Transactions related to the facilitating, clearing, or settling of trades for Alfa-Bank debt or equity, provided such trades were placed prior to 4:00 p.m. EST, April 6, 2022, until 12:01 a.m. EDT, June 30, 2022;47
  • Transactions related to the facilitating, clearing, or settling of trades for Alrosa debt or equity, provided such trades were placed prior to 4:00 p.m. EST, April 7, 2022, until 12:01 a.m. EDT, July 1, 2022;48
  • Wind down of derivative contracts entered into prior to 4:00 p.m. EST, February 24, 2022, that (i) include one of the VEB, Otkritie, Sovcombank, Sberbank, or VTB (and entities in which they own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest) as a counterparty or (ii) are linked to debt or equity of VEB, Otkritie, Sovcombank, Sberbank, or VTB (and entities in which they own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest) through 12:01 a.m. EDT, May 25, 2022, provided that any payments to a blocked person are made into a blocked account;49
  • Transactions related to wind down of derivative contracts entered into prior to 4:00 p.m. EDT, April 6, 2022, that (i) include Alfa-Bank or its subsidiaries as a counterparty or (ii) are linked to debt or equity of an entity in which it owns, directly or indirectly, a 50 percent or greater interest, through 12:01 a.m. EDT, June 30, 2022, provided that any payments to a blocked person are made into a blocked account;50
  • Transactions related to wind down of derivative contracts entered into prior to 4:00 p.m. EDT, April 7, 2022, that (i) include Alrosa or its subsidiaries as a counterparty or (ii) are linked to debt or equity of an entity in which it owns, directly or indirectly, a 50 percent or greater interest, through 12:01 a.m. EDT, July 1, 2022, provided that any payments to a blocked person are made into a blocked account;51
  • Transactions related to dealings in debt or equity of certain sovereign institutions specified in the GL ("Directive 4 entities") issued prior to March 1, 2022 through 12:01 a.m. EDT, May 25, 2022, provided that any divestment or transfer of, or facilitation of divestment or transfer of, covered debt or equity must be to a non-US person and the transaction must not involve a debit to an account in a US financial institution of the Directive 4 entity;52
  • Wind down of derivative contracts, repurchase agreements, or reverse repurchase agreements entered into prior to 12:01 a.m. EST, March 1, 2022, that involve a Directive 4 entity as a counterparty and the transaction must not involve a debit to an account in a US financial institution of the Directive 4 entity through 12:01 a.m. EDT May 25, 2022;53
  • US persons' payment of taxes, fees, or import duties, and purchase or receipt of permits, licenses, registrations, or certifications involving a Directive 4 entity, provided such transactions are ordinarily incident and necessary to such day-to-day operations in Russia until June 24, 2022;54
  • Transactions where a Directive 4 entity's sole function in the transaction is to act as an operator of a clearing and settlement system, provided that there is no transfer of assets to or from any Directive 4 entity, unless separately authorized; no Directive 4 entity is either a counterparty or a beneficiary to the transaction, unless separately authorized; and the transaction must not involve a debit to an account in a US financial institution of the Directive 4 entity;55
  • Transactions involving any entity owned 50 percent or more, directly or indirectly, by Alisher Burhanovich Usmanov that is not listed on OFAC's SDN list and unblocking all property and interests in property of the blocked Usmanov entities and authorizing debits to accounts on the books of a US financial institution of the blocked Usmanov entities;56
  • Transactions ordinarily incident and necessary to US imports of Russian-origin crude oil; petroleum; petroleum fuels, oils, and products of their distillation; liquefied natural gas; coal; and coal products pursuant to written contracts or written agreements entered prior to March 8, 2022 through 12:01 a.m. EDT, April 22, 2022;57
  • Transactions by US persons ordinarily incident and necessary to the official business of third-country diplomatic or consular missions located in the Russian Federation;58
  • Wind down of transactions ordinarily incident and necessary to the wind down of Sberbank CIB USA, Inc. and Alrosa USA, Inc. and any entity in which they own, directly or indirectly, a 50 percent or greater interest, including the processing and payment of salaries, severance, and expenses; payments to vendors and landlords; and closing of accounts, through 12:01 a.m. EDT, June 7, 2022;59
  • Wind down of transactions involving Sberbank of Russia or any entity in which it owns, directly or indirectly, a 50 percent or greater interest through 12:01 a.m. EDT, April 13, 2022;60
  • Wind down of transactions involving Alfa-Bank or any entity in which it owns, directly or indirectly, a 50 percent or greater interest through 12:01 a.m. EDT, May 6, 2022;61
  • Wind down of transactions involving Alrosa or any entity in which it owns, directly or indirectly, a 50 percent or greater interest through 12:01 a.m. EDT, May 7, 2022;62
  • Transactions ordinarily incident and necessary to the receipt or transmission of telecommunications involving Russia, as well as the export or reexport, sale, or supply, directly or indirectly, from the United States or by US persons to Russia of services, software, hardware, or technology incident to the exchange of communications over the internet, such as instant messaging, videoconferencing, chat and email, social networking, sharing of photos, movies, and documents, web browsing, blogging, web hosting, and domain name registration services;63
  • Wind down of transactions involving Joint Stock Company SB Sberbank Kazakhstan or Sberbank Europe AG, or any entity in which their subsidiaries own, directly or indirectly, a 50 percent or greater interest through 12:01 a.m. EDT, July 12, 2022;64
  • Certain transactions in support of nongovernmental organizations' activities, provided that the only involvement of blocked persons is the processing of funds by financial institutions blocked pursuant to EO 14024;65
  • Transactions involving Transkapitalbank or any entity in which it owns, directly or indirectly, a 50 percent or greater interest, that are ultimately destined for or originating from Afghanistan are authorized through 12:01 a.m. eastern daylight time, October 20, 2022;66 and
  • Wind down of transactions involving Transkapitalbank, or any entity in which it owns, directly or indirectly, a 50 percent or greater interest are authorized through 12:01 a.m. eastern daylight time, May 20, 2022.67

New and expanded Russia-related export restrictions

In response to Russia's actions in Ukraine, the US Department of Commerce's Bureau of Industry and Security (BIS) issued and modified several Russia-related export restrictions that are now codified in the Code of Federal Regulations. On February 24, 2022, the BIS issued new Russia license requirements and licensing policies. Commerce later imposed the same sanctions on Belarus and further restricted the availability of certain licenses. BIS has since amended and expanded the existing sanctions to target certain entities, exclude additional partner countries, target the Russian oil refinery sector and luxury goods destined for Russia and Belarus. Current measures include:

  • New Commerce Control List (CCL)-based license requirements for Russia and Belarus. The February 24 final rule added new license requirements for Export Control Classification Numbers (ECCNs) to all categories of the CCL. Certain of these items, in 58 ECCNs with unilateral controls, were not previously controlled to Russia and include microelectronics, telecommunications items, sensors, navigation equipment, avionics, marine equipment and aircraft components. According to BIS, these restrictions should significantly impact Russia's ability to acquire items it cannot produce itself. On April 9, 2022, these restrictions were expanded to include Categories 0-2. Although the majority of items in these categories already required licenses for Russia and Belarus, the April 9 rule imposes new license requirements for items including certain composite materials, medical products containing certain toxins or genetically modified organisms, hydraulic fluids, pumps, valves, and lower-level machine tools.
  • More restrictive license review policy of denial for applications for exports, reexports to, or transfers within Russia in line with the license review policies of other sanctions adopted against Russia. Applications for the export, reexport, or transfer (in-country) of items that require a license for Russia will be reviewed, with certain limited exceptions, under a policy of denial. The categories reviewed on a case-by-case basis are applications related to health and safety, safety of flight, maritime safety, humanitarian needs, government space cooperation, civil telecommunications infrastructure, government-to-government activities and to support limited operations of partner country companies in Russia.
  • Restricted availability of license exceptions related to information security and aviation. Any aircraft registered in, owned, or controlled by, or under charter or lease by Russia or a national of Russia now has restricted use of License Exception AVS under § 740.15(a) and (b) of the Export Administration Regulations (EAR). This means that any flight of such aircraft into Russia after March 2, 2022 requires a BIS authorization. This measure is concurrent with the US Department of Transportation and the Federal Aviation Administration's blocking orders on Russian aircraft and airlines from entering and using all domestic US airspace. BIS has since started publicly listing commercial and private aircraft flying into Russia in violation of the EAR and warned that violations of the EAR can lead to enforcement action and possible criminal or civil fines—including jail time and loss of export privileges—under General Prohibition Ten. On April 7, 2022, BIS issued three temporary denial orders to terminate the rights of three Russian airlines to participate in transactions subject to the EAR for their ongoing violations.
  • Expansion of existing Russia "military end use" and "military end user" control scope to all items subject to the EAR. Restrictions on Russian 'military end users' and 'military end uses' now cover all items subject to the EAR with exceptions for: (i) food and medicine designated as EAR99; and (ii) items classified as ECCN 5A992.c or 5D992.c, so long as they are not for Russian "government end users" or Russian state-owned enterprises.
  • Addition of two new Foreign Direct Product (FDP) Rules specific to Russia and Russian "military end users." 
    • The new FDP rule for all of Russia (the Russia FDP rule) establishes a control over foreign-produced items that are: (i) the direct product of certain US-origin software or technology subject to the EAR; or (ii) produced by certain plants or major components thereof which are themselves the direct product of certain US-origin software or technology subject to the EAR. This control applies when it is known that the foreign-produced item is destined to Russia or will be incorporated into or used in the production or development of any part, component, or equipment produced in or destined to Russia. The Russia FDP rule does not apply to foreign-produced items that would be designated as EAR99 (items not listed on the CCL), which includes many consumer items used by the Russian people.
    • The new foreign direct product rule for Russian military end users (the Russia-MEU FDP rule) is more extensive than the Russia FDP rule. It applies to foreign-produced items that are: (i) the direct product of any software or technology subject to the EAR that is on the CCL; or (ii) produced by certain plants or major components thereof which are themselves the direct product of any US-origin software or technology on the CCL. Such items will be subject to the EAR and require a license if an entity with a footnote 3 designation on the Entity List is a party to the transaction, or if there is knowledge that the item will be incorporated into or used in the production or development of any part, component, or equipment produced, purchased, or ordered by any entity with a footnote 3 designation (which is established in this rule and described below) on the Entity List. These restrictions apply to all items, including those designated EAR99, with certain exceptions, and impose a license requirement for footnote 3-designated Russian military end users.
  • Partner country exclusion from Russia and Russia-MEU FDP rules. Certain partner countries that are adopting or have expressed intent to adopt substantially similar measures are not or will not be subject to the Russia and Russia-MEU FDP rules. Exports, reexports, and transfers (in-country) from the following countries are not subject to these rules: Australia, Austria, Belgium, Bulgaria, Canada, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Japan, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, the Netherlands, New Zealand, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, Switzerland and the United Kingdom.
  • Significant restriction on the use of EAR license exceptions for Russian and Belarusian exports, reexports and transfers (in-country). Only certain sections of the following license exceptions are available for exports to Russia and Belarus:
    • TMP (Temporary Imports, Exports, Reexports and Transfers in Country), for items for use by the news media;
    • GOV, for certain government activities;
    • TSU (Technology and Software Unrestricted), for software updates to civil end users that are subsidiaries of, or joint ventures with, companies headquartered in the United States or partner countries;
    • BAG (Baggage), for baggage, excluding firearms and ammunition;
    • AVS (Aircraft, Vessels and Spacecraft), excluding any aircraft registered in, owned, or controlled by, or under charter or lease by Russia or a Russian national;
    • ENC (Encryption Commodities, Software and Technology), for encryption items, for civil end users that are subsidiaries of, or joint ventures with, companies headquartered in the US or partner countries; and
    • CCD (Consumer Communication Devices), for consumer communication devices, but not if they are destined for government end users or certain individuals associated with the government.
  • Application of the Entity List footnote 3 designation and addition of 49 entities. Entity List footnote 3 indicates that the Russia-MEU FDP rule applies to that entity. Thus, a license is required to export, reexport, or transfer (in-country) all items subject to the EAR (including foreign-produced items under the Russia-MEU FDP rule) to these entities, with limited exceptions. BIS has also identified certain entities to whom footnote 3 applies. License applications for footnote 3-designated entities will be reviewed under a policy of denial in all cases. A total of 47 entities are being transferred from the MEU List to the Entity List and are being designated with footnote 3. In addition, BIS added two new Russian MEUs to the Entity List with a footnote 3 designation. Additional entities may be added in the future.
  • Expansion of the scope of the general prohibition on export, reexport, or transfer (in-country) of certain energy-related items. Concurrent with EO 14066, BIS expanded the scope of the prohibition to any item subject to the EAR listed in new supplement no. 4 to § 74668 to and within Russia and does not require a person to have "knowledge" that the item would be used directly or indirectly in Russia's energy sector. BIS clarifies here that for purposes of the Entity List entries that reference § 746.5, the license requirements set forth on the Entity List apply when items are used in the projects specified in § 746.5(a)(1)(i), but that exporters, reexporters, or transferors must also review the transaction against the license requirements in § 746.5(a)(1)(ii), as well as all other applicable EAR license requirements. A savings clause in the final rule indicates that shipments of items removed from eligibility for a License Exception or export, reexport, or transfer (in-country) without a license (NLR) as a result of this regulatory action that were en route aboard a carrier to a port of export, reexport, or transfer (in-country), on March 4, 2022, pursuant to actual orders for export, reexport, or transfer (in-country) to or within a foreign destination, may proceed to that destination under the previous eligibility for a License Exception or export, reexport, or transfer (in-country) without a license (NLR).
  • Sanctions on "luxury goods" destined for Russia and Belarus and for Russian and Belarusian oligarchs and malign actors. On March 11, 2022, BIS amended EAR § 746.10 with more expansive license requirements, restrictive license review policies, and restrictions on license exception eligibility for 'luxury goods' destined for Russia or Belarus and for Russian or Belarusian oligarchs and malign actors worldwide.

Task Forces Targeting Sanctions Evasion and Related Conduct

On March 2, 2022, US Attorney General Merrick Garland announced the formation of the interagency Task Force KleptoCapture to complement the Russian Elites, Proxies, and Oligarchs (REPO) multilateral task force involving Australia, Canada, Germany, France, Italy, Japan, the United Kingdom, and the European Commission. Task Force KleptoCapture deploys US prosecutorial and law enforcement resources to identify sanctions evasion and related criminal conduct. On April 5, 2022, the DOJ announced that a US$90 million yacht owned by sanctioned Russian oligarch Viktor Vekselberg was successfully seized by Spain at the request of the United States. This is Task Force KleptoCapture's first seizure of an asset belonging to a sanctioned individual with close ties to the Russian regime. Attorney General Garland noted, "It will not be the last."

Practical considerations

The OFAC sanctions described above principally impact transactions within the United States or involving US persons, including entities organized in the United States, US citizens and permanent residents located anywhere, and persons in the United States regardless of nationality. Non-US companies also can be impacted by these prohibitions to the extent their transactions involve a US nexus, such as payments processed through the United States, which often occurs with US dollar denominated transactions; US person employees, officers, or directors; or US-origin items. Further, non-US companies can, themselves, be subject to the risk of designation and blocking under EO 14024 (and other executive orders) for materially assisting, sponsoring, or providing financial, material, or technological support for, or goods or services to or in support of, certain activities, a person blocked pursuant to EO 14024 or (in certain circumstances) a blocked government.69

Therefore, both US and non-US companies should carefully assess the new risks and compliance challenges presented by the new and expanded sanctions. In particular, companies that have any touchpoints with Russia, Ukraine, Belarus or the surrounding area should evaluate existing and prospective contracts, operations and other business activities relating to such business dealings and determine whether any changes should be made in order to ensure that those activities do not run afoul of the sanctions or create potential secondary sanctions exposure. Now more than ever, given the US's vigorous stance on Russia, companies need to make sure that they have appropriate controls, policies and procedures in place, including rigorous due diligence and screening mechanisms and, where appropriate, IP or geolocation blocking procedures, to ensure compliance with the sanctions. Furthermore, companies need to carefully consider their existing and future contractual sanctions rights and obligations to ensure that they remain in compliance with such provisions, and that the provisions remain effective and appropriate for the particular business. 

Importantly, companies should continue to monitor the rapidly evolving Russia-related sanctions landscape so that they are well-positioned to respond to any additional sanctions. The Biden administration has made it abundantly clear that the US intends to impose additional measures should the situation continue to escalate. The United Kingdom,70 the European Union,71 and Canada72 also have imposed and/or announced respective sanctions relating to Russia.

As always, we will continue to monitor these developments and issue additional briefings as warranted.


Footnotes

1   The White House, “Executive Order to Impose Costs for President Putin’s Action to Recognize So-Called Donetsk and Luhansk People’s Republics” (Feb. 21, 2022), available at https://www.whitehouse.gov/briefing-room/presidential-actions/2022/02/21/executive-order-on-blocking-property-of-certain-persons-and-prohibiting-certain-transactions-with-respect-to-continued-russian-efforts-to-undermine-the-sovereignty-and-territorial-integrity-of-ukraine/.

2   OFAC, “Ukraine General License Number 18” (Feb. 21, 2022), available at https://home.treasury.gov/system/files/126/ukraine_gl18.pdf.

3   OFAC, “Ukraine General License Number 19” (Feb. 21, 2022), available at https://home.treasury.gov/system/files/126/ukraine_gl19.pdf.

4   OFAC, “Ukraine General License Number 20” (Feb. 21, 2022), available at https://home.treasury.gov/system/files/126/ukraine_gl20.pdf.

5   OFAC, “Ukraine General License Number 21” (Feb. 21, 2022), available at https://home.treasury.gov/system/files/126/ukraine_gl21.pdf.

6   OFAC, “Ukraine General License Number 22” (Feb. 21, 2022), available at https://home.treasury.gov/system/files/126/ukraine_gl22.pdf.

7   OFAC, “Ukraine General License Number 23” (Feb. 21, 2022), available at https://home.treasury.gov/system/files/126/ukraine_gl23.pdf.

8   OFAC, “Ukraine General License No. 24” (Mar. 18, 2022), available at https://home.treasury.gov/system/files/126/ukraine_gl24.pdf.

9   OFAC, “Ukraine General License No. 25” (Mar. 24, 2022), available at https://home.treasury.gov/system/files/126/ukraine_gl25.pdf.

10   OFAC, “Russia General License No. 17A” (Mar. 24, 2022), available at https://home.treasury.gov/system/files/126/russia_gl17a.pdf.

11   OFAC, "Russia General License No. 17A" (Mar. 24, 2022), available at https://home.treasury.gov/system/files/126/russia_gl17.pdf.

12   OFAC, "Russia General License No. 18" (Mar. 11, 2022), available at https://home.treasury.gov/system/files/126/russia_gl18.pdf.

13   OFAC, "Russia General License No. 19" (Mar. 11, 2022), available at https://home.treasury.gov/system/files/126/russia_gl19.pdf.

15   US Dep't of Treasury, "U.S. Treasury Announces Unprecedented & Expansive Sanctions Against Russia, Imposing Swift and Severe Economic Costs" (Feb. 24, 2022), https://content.govdelivery.com/accounts/USTREAS/bulletins/30c2a69.

16   The White House, "Fact Sheet: Joined by Allies and Partners, the United States Imposes Devastating Costs on Russia" (Feb. 24, 2022), available at https://www.whitehouse.gov/briefing-room/statements-releases/2022/02/24/fact-sheet-joined-by-allies-and-partners-the-united-states-imposes-devastating-costs-on-russia/.

17   The White House, "Fact Sheet: Joined by Allies and Partners, the United States Imposes Devastating Costs on Russia" (Feb. 24, 2022), available at https://www.whitehouse.gov/briefing-room/statements-releases/2022/02/24/fact-sheet-joined-by-allies-and-partners-the-united-states-imposes-devastating-costs-on-russia/.

18   US Dep't of Treasury, "U.S. Treasury Imposes Sanctions on Russian Federation President Vladimir Putin and Minister of Foreign Affairs Sergei Lavrov" (Feb. 25, 2022), available at https://home.treasury.gov/news/press-releases/jy0610.

19  

The White House, "Fact Sheet: United States, European Union, and G7 to Announce Further Economic Costs on Russia" (Mar. 11, 2022), available at https://www.whitehouse.gov/briefing-room/statements-releases/2022/03/11/fact-sheet-united-states-european-union-and-g7-to-announce-further-economic-costs-on-russia/.

20   US Dep't of Treasury, "U.S. Treasury Sanctions Russia's Defense-Industrial Base, the Russian Duma and Its Members, and Sberbank CEO" (Mar. 24, 2022), available at https://home.treasury.gov/news/press-releases/jy0677.

21   US Dep't of Treasury, "U.S. Treasury Escalates Sanctions on Russia for Its Atrocities in Ukraine" (Apr. 6, 2022), available at https://home.treasury.gov/news/press-releases/jy0705.

22   US Dep't of Treasury, "The United States Sanctions Major Russian State-Owned Enterprises" (Apr. 7, 2022), available at https://home.treasury.gov/news/press-releases/jy0707.

23   The White House, "Fact Sheet: Joined by Allies and Partners, the United States Imposes Devastating Costs on Russia" (Feb. 24, 2022), available at https://www.whitehouse.gov/briefing-room/statements-releases/2022/02/24/fact-sheet-joined-by-allies-and-partners-the-united-states-imposes-devastating-costs-on-russia/.

24   OFAC, "Directive 2 Under Executive Order 14024" (Feb. 24, 2022), available at https://home.treasury.gov/system/files/126/correspondent_accounts_directive_2.pdf.

25   OFAC FAQ # 971. OFAC's Ukraine-/Russia-Related FAQs can be found at https://home.treasury.gov/policy-issues/financial-sanctions/faqs/topic/1576.

26   OFAC, "List of Foreign Financial Institutions Subject to Correspondent Account or Payable-Through Account Sanctions (CAPTA List)," available at https://home.treasury.gov/policy-issues/financial-sanctions/consolidated-sanctions-list-non-sdn-lists/list-of-foreign-financial-institutions-subject-to-correspondent-account-or-payable-through-account-sanctions-capta-list (last updated Feb. 24, 2022).

27   US Dep't of Treasury, "Treasury Prohibits Transactions with Central Bank of Russia and Imposes Sanctions on Key Sources of Russia's Wealth" (Feb. 28, 2022), available at https://home.treasury.gov/news/press-releases/jy0612. See also OFAC, "Russia-related Directive 4" (Feb. 28, 2022), available at https://home.treasury.gov/system/files/126/eo14024_directive_4_02282022.pdf.

28   OFAC, "Russia General License No. 8B" (Apr. 6, 2022), available at https://home.treasury.gov/system/files/126/russia_gl8b.pdf.

29   OFAC, "Directive 3 Under Executive Order 14024" (Feb. 24, 2022), available at https://home.treasury.gov/system/files/126/new_debt_and_equity_directive_3.pdf.

30   OFAC FAQ # 986.

31   OFAC FAQ # 984.

32   OFAC FAQ # 989.

33   OFAC FAQ # 985.

34   OFAC FAQ # 989.

36   OFAC, "Directive 1A Under Executive Order 14024" (Feb. 22, 2022), available at https://home.treasury.gov/system/files/126/russia_directive_1a.pdf.

37   OFAC FAQ # 965. See OFAC FAQ # 888 for additional details on the effective dates of the prohibitions.

38   OFAC FAQ # 891.

39   U.S. Dep't of Treasury, "Determination" (Feb. 22, 2022), available at https://home.treasury.gov/system/files/126/russia_harmful_determination_20220222.pdf.

40   OFAC, "Russia General License No. 2" (Feb. 22, 2022), available at https://home.treasury.gov/system/files/126/russia_gl2.pdf.

41   OFAC, "Russia General License No. 6A" (Mar. 24, 2022), available at https://home.treasury.gov/system/files/126/russia_gl6a.pdf.

42   OFAC, "Russia General License No. 7" (Feb. 24, 2022), available at https://home.treasury.gov/system/files/126/russia_gl7.pdf.

43   The term "related to energy" means the extraction, production, refinement, liquefaction, gasification, regasification, conversion, enrichment, fabrication, transport, or purchase of petroleum, including crude oil, lease condensates, unfinished oils, natural gas liquids, petroleum products, natural gas, or other products capable of producing energy, such as coal, wood, or agricultural products used to manufacture biofuels, or uranium in any form, as well as the development, production, generation, transmission, or exchange of power, through any means, including nuclear, thermal, and renewable energy sources.

44   OFAC, "Russia General License No. 8B" (Apr. 6, 2022), available at https://home.treasury.gov/system/files/126/russia_gl8b.pdf.

45   OFAC, "Russia General License No. 9C" (Apr. 7, 2022), available athttps://home.treasury.gov/system/files/126/russia_gl9c.pdf.

46   OFAC, "Russia General License No. 9C" (Apr. 7, 2022), available at https://home.treasury.gov/system/files/126/russia_gl9c.pdf.

47   OFAC, "Russia General License No. 9C" (Apr. 7, 2022), available at https://home.treasury.gov/system/files/126/russia_gl9c.pdf.

48  

OFAC, "Russia General License No. 9C" (Apr. 7, 2022), available at https://home.treasury.gov/system/files/126/russia_gl9c.pdf.

49   OFAC, "Russia General License No. 10C" (Apr. 7, 2022), available at https://home.treasury.gov/system/files/126/russia_gl10c.pdf.

50   OFAC, "Russia General License No. 10C" (Apr. 7, 2022), available at https://home.treasury.gov/system/files/126/russia_gl10c.pdf.

51   OFAC, "Russia General License No. 10C" (Apr. 7, 2022), available at https://home.treasury.gov/system/files/126/russia_gl10c.pdf.

52   OFAC, "Russia General License No. 14" (Mar. 2, 2022), available at https://home.treasury.gov/system/files/126/russia_gl14.pdf.

53   OFAC, "Russia General License No. 10C" (Apr. 7, 2022), available at https://home.treasury.gov/system/files/126/russia_gl10C.pdf.

54   OFAC, "Russia General License No. 13" (Mar. 2, 2022), available at https://home.treasury.gov/system/files/126/russia_gl13.pdf.

55   OFAC, "Russia General License No. 14" (Mar. 2, 2022), available at https://home.treasury.gov/system/files/126/russia_gl14.pdf.

56   OFAC, "Russia General License No. 15" (Mar. 2, 2022), available at https://home.treasury.gov/system/files/126/russia_gl15.pdf.

57   OFAC, "Russia General License No. 16" (Mar. 8, 2022), available at https://home.treasury.gov/system/files/126/russia_gl16.pdf.

58   OFAC, "Russia General License No. 20" (Mar. 24, 2022), available at https://home.treasury.gov/system/files/126/russia_gl20.pdf.

59   OFAC, "Russia General License No. 21A" (Apr. 6, 2022), available at https://home.treasury.gov/system/files/126/russia_gl21a.pdf.

60   OFAC, "Russia General License No. 22" (Apr. 6, 2022), available at https://home.treasury.gov/system/files/126/russia_gl22.pdf.

61  

OFAC, "Russia General License No. 23" (Apr. 6, 2022), available at https://home.treasury.gov/system/files/126/russia_gl23.pdf.

62   OFAC, "Russia General License No. 24" (Apr. 7, 2022), available at https://home.treasury.gov/system/files/126/russia_gl24.pdf.

63  

OFAC, "Russia General License No. 25" (Apr. 7, 2022), available at https://home.treasury.gov/system/files/126/russia_gl25.pdf.

64   OFAC, "Russia General License No. 26" (Apr. 12, 2022), available at https://home.treasury.gov/system/files/126/russia_gl26.pdf.

65   OFAC, "Russia General License No. 27" (Apr. 19, 2022), available at https://home.treasury.gov/system/files/126/russia_gl27.pdf.

66   OFAC, "Russia General License No. 28" (Apr. 20, 2022), available at https://home.treasury.gov/system/files/126/russia_gl28.pdf.

67   OFAC, "Russia General License No. 29" (Apr. 20, 2022), available at https://home.treasury.gov/system/files/126/russia_gl29_0.pdf.

68   The March 4 final rule (15 C.F.R. § 746) indicates that the new supplement no. 4 to §746 has been added and referenced in footnote 6 of the Commerce Country Chart to offer both Harmonized Tariff Schedule (HTS)-6 codes and Schedule B numbers for all exports, reexports, and transfers (in-country) to or within Russia to assist exporters, reexporters, and transferors if they have difficulty in identifying a product based on either the HTS codes or Schedule B numbers alone.

69   OFAC FAQ # 980.

70   Gov't of the United Kingdom, "PM statement on the situation in Ukraine: 22 February 2022" (Feb. 22, 2022), available at https://www.gov.uk/government/speeches/pm-statement-on-the-situation-in-ukraine-22-february-2022.

71   Council of the European Union, "EU adopts package of sanctions in response to Russian recognition of the non-government controlled areas of the Donetsk and Luhansk oblasts of Ukraine and sending of troops into the region" (Feb. 23, 2022), available at https://www.consilium.europa.eu/en/press/press-releases/2022/02/23/russian-recognition-of-the-non-government-controlled-areas-of-the-donetsk-and-luhansk-oblasts-of-ukraine-as-independent-entities-eu-adopts-package-of-sanctions/.

72   Prime Minister of Canada, "Canada announces support to address the situation in Ukraine" (Feb. 22, 2022), available at https://pm.gc.ca/en/news/news-releases/2022/02/22/canada-announces-support-address-situation-ukraine.



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