Check out the latest episode of The Justice Insiders—a podcast hosted by Husch Blackwell partner Gregg Sofer—where we explore the intersection of international trade law and government investigations and enforcement, particularly in connection with Russia. I previously appeared on Gregg’s podcast during the first quarter of 2022, and we pick up that conversation in order to update listeners on the evolution of U.S. trade policy over the past year and the impact those policy decisions have had on private businesses ..read more

We are pleased to announce that our team’s fourth-annual international trade law year-in-review report was published just before the New Year. In it, we take a detailed look at how 2022 played out and explore how 2023 might develop. As companies continue to work through the challenges associated with supply chain dislocations, geopolitical turmoil, and evolving trade policy, regulation, and enforcement, we hope the framework presented in our report will help your business maximize potential cost savings and minimize potential risks ..read more

BIS Adds 24 New Entities and Removes One from Entity List On December 8, 2022, the Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a notice in the Federal Register adding 24 entities under 26 entries and removing one entity from the Entity List. The entities are from Latvia, Pakistan, Russia, Singapore, Switzerland, and the United Arab Emirates.   Entities assisting Russia The following entities were added to the Entity List because of their significant contributions to Russia’s military and defense industries: Latvia Fiber Optic Solutions Russia AO Kraftway ..read more

On May 8, 2022 the U.S. Department of the Treasury’s (“Treasury”) Office of Foreign Assets Control (“OFAC”) further escalated U.S. sanctions against the Russian Federation (“Russia”) by issuing two Determinations, adding new individuals and entities to the Specially Designated Nationals and Blocked Persons list (“SDN List”), and issuing three new general licenses in connection with the Determinations and SDN List designations.  Among those newly designated as SDNs by OFAC are three state-controlled Russian television stations; Russian-state bank Joint Stock Company Moscow Industrial Bank ..read more

On May 9, 2022, the Bureau of Industry and Security (“BIS”) released for public inspection a Final Rule adding hundreds of new items to a list of restricted items in Supplement No. 4 to Part 746 of the U.S. Export Administration Regulations (“EAR”).  BIS created the Supplement No. 4 list two months ago in March 2022 to prohibit the export, reexport, or in-country transfer to or within Russia of specified items included on the list. (Husch Blackwell has previously provided more in-depth guidance on this here)  The Supplement No. 4 list is one of two (2) Russia Industry Sector Sanction ..read more

This blog post covers several new sanctions and export controls that the U.S. government imposed on Russia and Belarus in the time period occurring between March 31, 2022 and April 21, 2022.  As regular readers are aware, these restrictions are subject to frequent and sudden change.  For summaries of previously imposed sanctions and coverage on any future sanctions announcements concerning Russia, Belarus and Ukraine, we recommend that you visit the Husch Blackwell Russia Sanctions Resource Library.   Presidential Proclamation on April 21, 2022 Banning Russian-Affiliated Vessels ..read more

On March 30, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) modified and expanded a list of aircraft that have flown into Russia in apparent violation of the Export Administration Regulations (“EAR”).  We more thoroughly discussed the implications of this list – which was first published on March 18, 2022 – in our blog post here.  The updated list adds 73 additional Boeing-manufactured aircraft and modifies tail and/or serial number information for 13 aircraft previously listed on March 18, 2022.  The full list of owners/operators include Aeroflo ..read more

On March 24, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) updated the Specially Designated Nationals and Blocked Persons List (“SDN List”) with hundreds of new designations pursuant to Executive Order 14024.  The new SDNs include: The Russian Federation (“Russia”) State Duma (lower house of the Russian legislature) as an entity; More than three hundred members of the Russian State Duma in their individual capacities; Seventeen (17) members of the board of PJSC Sovcombank (previously designated as a SDN); Numerous Russian elites, most notably Genna ..read more

On March 18, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) publicly identified certain commercial and private aircraft that have entered Russia in likely violation of the Export Administration Regulations (“EAR”).  BIS provided an initial listing of nearly 100 Boeing aircraft owned and/or operated by Aeroflot, AirBridgeCargo, Aviastar-TU, Azur Air, Nordwind, and Utair (in addition to one Gulfstream G650ER owned by Roman Abramovich).  Secretary of Commerce Gina M. Raimondo was quoted in the press release as stating:  “We are publishing this list ..read more

On Friday, March 11, 2022, the White House issued Executive Order (“EO”) 14068 announcing more sanctions and export controls against the Russian Federation (“Russia”).  Concurrent with that announcement, the U.S. Commerce Department’s Bureau of Industry and Security (“BIS”) released new export controls restricting the flow of “luxury goods” to Russia, Belarus, and Russian/Belarusian “oligarchs and malign actors” while the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued dozens of Specially Designated Nationals and Blocked Persons List (“SDN List”) designations a ..read more