News 24 Jun. 2021
Curtis successfully defends foreign states' procedural privileges in the UK Supreme Court
more
News 23 Jun. 2021
Ibrahim Elsadig joins Curtis as Partner in Dubai
Client Alert 24 Feb. 2022
EU, UK, Japan and Australia Impose Sanctions on Russia
News 09 Aug. 2021
Curtis, Mallet-Prevost, Colt & Mosle enters into association with Chevalier Law in Singapore.
News 06 May. 2022
Curtis Advises Terna Group on the Sale of its Latin America Power Transmission Assets to CDPQ
Publications 05 May. 2022
Marie-Claire Argac, Simon Batifort, and Cyprien Mathié share highlights from “Affaires d’Etats: Practical Considerations When Defending States in International Arbitration” on Kluwer Arbitration Blog
Event 26 Apr. 2022
Claudia Frutos-Peterson Speaks at CAI Costa Rica’s 13th Congress of International Arbitration
News 21 Apr. 2022
SCOTUS Upholds U.S. Colonialism under the U.S. Constitution
Client Alert 23 Mar. 2022
The Dubai International Arbitration Centre (DIAC) has launched the DIAC Arbitration Rules 2022
Event 22 Nov. 2021
Partner Antonia Birt spoke at ADGMAC and AIAC Webinar Series: Webinar 5 - Disputes in Fintech and Complex Technology in MESEA
News 19 May. 2022
Eliot Lauer’s and Juan Perla’s Tenth Circuit Arguments Featured on Audio Arguendo Podcast
News 16 May. 2022
Curtis Files SCOTUS Amicus Brief for Ohio Justice & Policy Center in Prisoners’ Rights Case
Client Alert 21 Apr. 2022
New Laws Targeting Assets of Russian Oligarchs: The U.S. Announces Task Force KleptoCapture and the Kleptocracy Asset Recovery Rewards Program
Client Alert 19 Apr. 2022
U.S. President Biden Expands Export Controls Imposed on Russia and Belarus
Client Alert 24 Jun. 2021
Update on Virtual Notarization (Executive Order 202.7) During the COVID-19 (Coronavirus) Pandemic (Updated: June 24, 2021) — U.S. Insight
Update on Virtual Witnessing (New York Executive Order 202.14) During The COVID-19 (Coronavirus) Pandemic (Updated: June 24, 2021) — U.S. Insight
Client Alert 14 Apr. 2022
The full alert is available for download with footnotes here
On April 6, 2022, President Biden issued an executive order titled “Prohibiting New Investment in and Certain Services to the Russian Federation in Response to Continued Russian Federation Aggression” (hereafter, “E.O. 14071”).
In addition, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) released the following updates: (1) added two of Russia’s largest banks and a Russian state-owned mining company to the Specially Designated Nationals and Blocked Persons List (“SDN List”), (2) issued new and amended General Licenses related to the Russian banks and mining company, (3) added several other parties to the SDN List, and (4) issued a General License related to telecommunications.
E.O. 14071 expands upon prior restrictions on new investment in the Russian energy sector (see Curtis Client Alert) by banning all new investments in Russia—regardless of sector. Specifically, E.O. 14071 prohibits the following:
The term “new investment” is not defined in the Executive Order. An FAQ published by OFAC in connection with related E.O. 14066 of March 8, 2022 defines “investment” as a “transaction that constitutes a commitment or contribution of funds or other assets for, or a loan or other extension of credit.”
It remains to be seen whether OFAC will apply the same interpretation to E.O. 14071. Curtis will monitor OFAC’s implementation of the sanctions.
Relying on the authorization granted by E.O. 14024 of April 15, 2021, OFAC added the following entities to the SDN List: Public Joint Stock Company Sberbank of Russia (“Sberbank”) and 42 of its subsidiaries, and Joint Stock Company Alfa-Bank (“Alfa-Bank”) and six of its subsidiaries.
All entities owned 50 percent or more, directly or indirectly, by Sberbank or Alfa-Bank will be blocked under E.O. 14024, even if not explicitly designated by OFAC.
Note that while certain transactions with Sberbank and Alfa-Bank were already prohibited by U.S. sanctions (i.e., pursuant to Directive 2 under E.O. 14024 for Sberbank, and pursuant to Directive 3 under E.O. 14024 for Alfa-Bank), they had not been designated on the SDN List.
In addition, OFAC has added Public Joint Stock Company Alrosa (“Alrosa”), a Russian state-owned enterprise, to the SDN List. Alrosa is the world’s largest diamond mining company, which is also responsible for 90 percent of Russia’s diamond mining capacity.
Furthermore, OFAC added United Shipbuilding Corporation, a major Russian shipbuilder, and its subsidiaries to the SDN List as well.
Related to the addition of Sberbank, Alfa-Bank, and Alrosa to the SDN List, OFAC has also issued new General Licenses and amended General Licenses to cover certain transactions with Sberbank, Alfa-Bank, and Alrosa.
On April 5, 2022, OFAC added Garantex Europe OU (“Garantex”) and Hydra Market, along with over 100 of its associated virtual currency addresses, to the SDN List. Garantex is a virtual currency exchange founded in 2019, and Hydra is a Russian darknet market launched in 2015.
Furthermore, OFAC added several family members of Russian government officials, most notably President Vladimir Putin’s two daughters, Katerina Vladimirovna Tikhonova and Maria Vladimirovna Vorontsova.
Additionally, all members of the Russian Security Council have now been added to the SDN List pursuant to E.O. 14024.
On April 7, 2022, OFAC issued General License 25 authorizing certain transactions “ordinarily incident and necessary to the receipt or transmission of telecommunications involving the Russian Federation.”
In addition, General License 25 authorizes the “exportation or reexportation, sale, or supply, directly or indirectly, from the United States or by U.S. persons, wherever located, to the Russian Federation 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, that is prohibited by the [Russian Harmful Foreign Activities Sanctions Regulations].”
Curtis will continue to monitor developments in this rapidly changing area.
International Trade
Economic Sanctions
Jacques Semmelman
Partner
Jason D. Wright
Ana Amador
Associate
John Taishu Pitt
Trade Analyst
Lorena Guzmán-Díaz
Marwa Farag
New York
+1 212 696 6000
Event 12 Apr. 2022
US, EU, and UK Sanctions and Export Controls Imposed Against Russia: What Every Business Should Know
Client Alert 15 Mar. 2022
U.S. President Biden Imposes Fifth Tranche of Economic Sanctions Against Russia
U.S. President Biden Imposes a Fourth Tranche of Economic Sanctions Against Russia
We use cookies on our website to enhance your browsing experience, match your interests and assess our website performance. We do not share information with any third-party for marketing purposes. Please view our privacy policy to learn more about the use of cookies on our website. By continuing to browse our website, you consent to our use of cookies.