On February 23, 2024, the United States issued a broad set of new Russia-related sanctions and export controls in response to the second anniversary of Russia’s invasion of Ukraine and the February 16, 2024, death of opposition leader, Aleksey Navalny, in Russian custody. The Treasury Department’s Office of Foreign Assets Control (OFAC), the Commerce Department’s Bureau of Industry and Security (BIS), and the State Department all issued new designations.  The agencies also issued an inter-agency advisory warning non-Russian companies from doing business in or with Russia. Treasury Departm ..read more

The UK government introduced new reporting requirements under The Russia (Sanctions) (EU Exit) Regulations 2019 (“Russia Regulations”) in December 2023, with the goal of strengthening transparency in relation to assets frozen under the regime and assisting HM Treasury’s Office of Financial Sanctions Implementation (“OFSI”) to monitor compliance with, and detect evasion of, financial sanctions administered under the Russia regime.  The two new reporting measures are the immobilized assets reporting measure and the designated persons asset reporting measure.  On February 12, 2024, OFSI ..read more

On December 22, 2023, President Biden issued a new Executive Order (“EO”) 14114 “Taking Additional Steps With Respect to the Russian Federation’s Harmful Activities” which amended EOs 14024 and 14068. These amendments introduce the authority to impose secondary sanctions with respect to foreign (i.e., non-US) financial institutions determined to have engaged in any significant transaction for or on behalf of certain entities designated under EO 14024, or to have engaged in any significant transaction or provided any service involving the Russian military-industrial base (which is broadly defin ..read more

On December 11, 2023, the UK’s Department for Business & Trade (“DBT”) published a General Trade Licence of indefinite duration concerning measures related to third-country processed iron and steel, pursuant to The Russia (Sanctions) (EU Exit) Regulations 2019 (the “Russia Regulations”) (the “GL”).  The GL has been introduced to provide additional clarity in key areas for traders navigating these sanctions. Background In April 2023, the UK government legislated for a prohibition on certain activities involving Russian iron and steel products processed in a third country in The Russia ..read more

On December 14, 2023, the UK government issued new Russia sanctions legislation under The Russia (Sanctions) (EU Exit) (Amendment) (No.4) Regulations 2023 (“Amendment No. 4”) and The Russia (Sanctions) (EU Exit) (Amendment) (No.5) Regulations 2023 (“Amendment No. 5”).  The new sanctions make good on commitments made by the United Kingdom as part of the G7 earlier in 2023 such as sanctions targeting Russian diamonds and metals.  The package also includes new financial sanctions restrictions on the provision of correspondent banking and payment processing by UK credit and financial ins ..read more

On December 6, 2023, the UK’s National Economic Crime Centre (“NECC”) issued a red alert concerning the export of high-risk goods that Russia is using on the battlefield in Ukraine.  The red alert outlines sanctions evasion red flags for the financial services, transportation, and logistics sectors, including features of suspicious transactions, customers, requested services, and items.  In addition, HM Treasury’s Office of Financial Sanctions Implementation (“OFSI”) has designated 46 individuals and entities based in Russia, Belarus, China, Serbia, Turkey, the United Arab Emirates ..read more

On September 14, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), the Department of State, and the Department of Commerce’s Bureau of Industry and Security (“BIS”) announced new sanctions designations and export control guidance related to Russia.  These developments are the latest updates in the U.S. government’s ever-evolving response to Russia’s war in Ukraine through economic sanctions and export controls. Sanctions Designations OFAC announced the imposition of sanctions on nearly 100 individuals and entities that purportedly benefit from, support ..read more

On September 8, 2023, the UK Departments for Business and Trade and International Trade jointly published guidance on the scope of the sanctions on certain Russian iron and steel products processed in a third country that will come into effect under Part 5, Chapter 4CA of The Russia (Sanctions) (EU Exit) Regulations 2019 (“Russia Regulations”) on September 30, 2023 (“Guidance”).  The measure seeks to reduce circumvention of sanctions on the covered Russian iron and steel products by limiting market participants’ ability to conceal the Russian origin of these items through third country pr ..read more

On August 18, 2023, the UK High Court issued a judgment in the first sanctions designation challenge pursuant to the UK’s Russia sanctions regime under Section 38 of the Sanctions and Anti-Money Laundering Act 2018 (“SAMLA”).  The challenge was brought by Eugene Shvidler (“Mr. Shvidler”), a UK-US dual national businessman, following an unsuccessful ministerial review in which Mr. Shvidler sought to reverse his UK designation.  The High Court rejected the challenge on the grounds that the decision to maintain Mr. Shvidler’s designation was proportionate and non-discriminator ..read more

On May 22, 2023, the Department for Business and Trade’s Export Control Joint Unit published new guidance on trade sanctions circumvention under the UK’s Russia sanctions regime (the “Guidance”).  While direct trade between the UK and Russia reportedly has fallen significantly since the introduction of a broad package of trade sanctions in response to Russia’s invasion of Ukraine, there is a growing associated risk of displacement of trade and diversion of goods to Russia via indirect routes. The Guidance seeks to prevent the trade sanctions, export controls, and other measures implemente ..read more