News 09 Apr. 2024
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News 25 Jan. 2024
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Event 18 Aug. 2023
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News 25 Jul. 2023
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Client Alert 28 Dec. 2023
U.S. to Impose Secondary Sanctions on Non-U.S. Banks For Financing Russia’s Defense Industry
News 28 Aug. 2024
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Event 22 Aug. 2023
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News 31 Jul. 2023
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News 24 Aug. 2023
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Client Alert 10 Jul. 2024
EU Adopts New Restrictive Measures Against Belarus
Client Alert 26 Jun. 2024
The EU Adopts its 14th Sanctions Package Against Russia
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Client Alert 11 Mar. 2022
Click here to download the full alert
On February 24, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) released a second tranche of sanctions against Russian individuals and entities. These measures followed the comprehensive jurisdiction-based sanctions imposed on DNR and LNR on February 21, 2022, sanctions related to the Russian financial sector imposed on February 22, 2022, and sanctions on Nord Stream 2 G imposed on February 23, 2022.
The second tranche includes two new directives. OFAC Directive 2, issued under E.O. 14024, prohibits U.S. financial institutions from opening or maintaining a correspondent account or payable-through account for or on behalf of PJSC Sberbank of Russia and 25 of its subsidiaries, effective March 26, 2022. Processing transactions involving Sberbank and its subsidiaries is also prohibited. OFAC may designate other foreign financial institutions under Directive 2. Sanctions against such financial institutions shall become effective 30 days after the designation.
OFAC Directive 3, also issued under E.O. 14024, prohibits U.S. persons from engaging in all transactions in, providing financing for, and other dealings in new debt of longer than 14 days’ maturity or new equity issued on or after 12:01 a.m. Eastern Daylight Time, March 26, 2022, by 13 Russia-related entities:
OFAC defines debt to include “bonds, loans, extensions of credit, loan guarantees, letters of credit, drafts, bankers acceptances, discount notes or bills, or commercial paper” and equity to include “stocks, share issuances, depositary receipts, or any other evidence of title or ownership.”
OFAC may designate other foreign entities under Directive 3, which will be named on OFAC’s CAPTA List. Sanctions against such financial institutions shall become effective 30 days after the designation.
Additions to the SDN List
On February 24, 2022, OFAC also added approximately 70 individuals and entities to the SDN List pursuant to E.O. 14024. A full list is available here.
Enforcement
The U.S. Department of Justice announced a new task force aimed at enforcing sanctions on Russian oligarchs. Task Force KleptoCapture will be led by Andrew Adams, a veteran Assistant U.S. Attorney for the Southern District of New York. The interagency law enforcement group will be responsible for investigating and prosecuting sanctions violations.
The task force will be run out of the Office of the Deputy Attorney General, and will include attorneys from the National Security, Criminal, Tax and Civil Divisions of the Department of Justice, as well as from U.S. Attorneys’ Offices across the country. The task force will also include agents and analysts from the Federal Bureau of Investigation, the U.S. Marshals Service, the Internal Revenue Service, the Postal Inspection Service, the Department of Homeland Security, the Secret Service, and other agencies.
The Department of Justice announced that Task Force KleptoCapture will cooperate with a transatlantic task force that was announced by President Biden and European allies on February 26, 2022.
No further information about the transatlantic task force has been made available.
Economic Sanctions
International Trade
Ana Amador
Associate
Jason D. Wright
Partner
Marwa Farag
John Taishu Pitt
Trade Analyst
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client alert
Expanded Sanctions Imposed on Belarus by the U.S., EU, and UK
EU/UK Expand Sanctions against Russia
U.S. President Biden Imposes Export Controls on Russia and Belarus
EU and the UK Impose Further Sanctions on Russia
EU, UK, Japan and Australia Impose Sanctions on Russia
OFAC Imposes Sanctions on Russian Persons, Entities, and Vessels
President Joseph Biden Issues Executive Order Imposing U.S. Sanctions Against Russia Backed Regions in Eastern Ukraine
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