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Client Alert 15 Mar. 2022
THE FULL ALERT IS AVAILABLE FOR DOWNLOAD WITH FOOTNOTES HERE.
On March 2, 2022, U.S. President Joseph Biden announced a new sanctions package against Russia and Belarus in coordination with its allies. The sanctions include blocking of assets of Russian military entities and elites, as well as a ban on Russian aircraft entering and using domestic U.S. airspace. We have issued a separate client alert on sanctions imposed against Belarus (here) and export control measures (here).
a. New Designations
The day after the U.S. President announced the new sanctions package, the U.S. Department of the Treasury issued new designations targeting (i) Russian “elites” and connected entities (e.g., Alisher Burhanovich Usmanov, his superyacht Dilbar, and his business jet; Nikolay Petrovich Tokarev; and Yevgeniy Prigozhin); (ii) media organizations that are said to be disseminating “misinformation” along with 26 employees and other persons and entities (e.g., Odna Rodyna; Rhythm of Eurasia; Journal Kamerton; New Eastern Outlook and Oriental Review; and United World International (UWI)). The designations were made in close coordination with the European Union, United Kingdom, Canada, Japan, South Korea and Australia.
The U.S. Department of State also listed Russian “elites” pursuant to Executive Order (E.O.) 14024 (including Boris Rotenberg and SMP Bank, Dmitry Peskov, Arkady Rotenberg, Sergei Chemezov, Igor Shuvalov, 14 members of their families, and seven connected entities). In addition, the U.S. Department of State designated 22 Russian defense-related entities under E.O. 14024 as persons who operate or have operated in the defense and related matériel sector or the technology sector of the Russian Federation economy. The designations include firms that make combat aircraft, infantry fighting vehicles, electronic warfare systems, missiles, and unmanned aerial vehicles for Russia’s military.
As a result of these designations, all property and interests in property of the listed individuals and entities that are in the United States or in the possession or control of U.S. persons are blocked. In addition, any entities that are owned, directly or indirectly, 50 percent or more by one or more blocked persons are also blocked. All transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or otherwise blocked persons are prohibited unless exempt or authorized by a general or specific license issued by OFAC. These prohibitions include the making of any contribution or the provision of funds, goods or services by, to, or for the benefit of any blocked person and the receipt of any contribution or the provision of funds, goods or services from any such person.
b. Ban on Russian Aircraft from Entering/Using U.S. Airspace
The U.S. Department of Transportation and its Federal Aviation Administration (“FAA”) have issued regulatory orders and a Notice to Air Mission (NOTAM) blocking Russian aircraft and airlines from entering and using all domestic U.S. airspace. The restriction is broad, and encompasses “all Russian air carriers and commercial operators, regardless of the state of registry of the aircraft; all aircraft registered in the Russian Federation; all Russian state aircraft, regardless of the state of registry of the aircraft; and all aircraft, regardless of the state of registry, owned, chartered, leased, operated or controlled by, for, or for the benefit of, a person who is a citizen of the Russian Federation.” The aviation measures effectively revoke the ability of all Russian airlines – passenger and cargo – to operate to and from U.S. destinations, as well as refusing entry of any Russian-operated aircraft into U.S. airspace. The only exception available is for the case of humanitarian or search and rescue operations specifically authorized by the FAA, diplomatic clearance by the U.S. Department of State and aircraft experiencing in-flight emergencies.
c. General Licenses
Over the past weeks, the U.S. Department of the Treasury has issued the following Russia-related General Licenses:
Attorney advertising. The material contained in this Client Alert is only a general review of the subjects covered and does not constitute legal advice. No legal or business decision should be based on its contents.
Jason D. Wright
John Taishu Pitt
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+1 202 452 7373
+32 2 313 37 31
+41 22 718 3500
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