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Click here to download the full alert with footnotes.
On June 28, 2022, the Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued a determination prohibiting gold of Russian origin from being imported to the United States.
The Department of Commerce’s Bureau of Industry and Security (“BIS”) and the Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a joint alert to financial institutions to aid in detecting potential violations of export controls.
In addition, OFAC made 70 new designations, BIS added 36 entities to its Entity List, and the State Department made 74 new designations and imposed new visa restrictions.
For President Biden’s June 27 decision to raise the tariff rate on $2.3 billion worth of Russian imports to 35%, please see our Curtis Client Alert issued June 28, 2022.
OFAC issued a determination pursuant to Section 1(a)(i) of Executive Order (E.O.) 14068, which states that the “importation into the United States of gold of Russian Federation origin is prohibited.” This determination took effect on June 28, 2022.
This determination specifically “excludes gold of Russian Federation origin that was located outside of the Russian Federation prior to the effective date of this determination.” Certain gold-related transactions involving Russia were already sanctionable under E.O. 14024 before this determination.
The determination was part of a coordinated sanctions package released following the conclusion of the Group of Seven (G-7) summit in Germany. To date, three other G-7 members, Canada, Japan, and the UK, have announced similar bans on imports of Russian-origin gold.
OFAC designated 70 entities, including State Corporation Rostec, which OFAC described as the “cornerstone of Russia’s defense, industrial, technology, and manufacturing sectors,” as well as 29 Russian individuals. For the complete list of designations, please see the Department of Treasury’s press release.
In tandem with OFAC’s designations, the Department of State imposed sanctions on 45 entities and 29 individuals under E.O. 14024, including 19 board members of Rostec and nine of their adult family members. Additionally, the Department of State imposed visa restrictions on 511 Russian military officers.
OFAC also issued General Licenses 39 – 43:
General License 39:
General License 40:
General License 41:
General License 42:
General License 43:
BIS amended the EAR by adding 36 entities to the Entity List. The Entity List publishes the names of foreign persons that are subject to specific license requirements for the export, reexport, and/or transfer of specified items. These entities will be listed on the Entity List under the following destinations: China, Lithuania, Pakistan, Russia, Singapore, the United Arab Emirates, the United Kingdom, Uzbekistan, and Vietnam. Please see the BIS website for the most updated Entity List.
In addition, FinCEN and BIS issued a joint alert to provide financial institutions with an overview of BIS’s current export restrictions; a list of commodities of concern for possible export control evasion; and select transactional and behavioral red flags to assist financial institutions in identifying related suspicious transactions.
The joint alert reminds financial institutions of their obligations under the Bank Secrecy Act (“BSA”) to report suspicious activity to FinCEN. The alert provides Suspicious Activity Report (“SAR”) filing instructions for suspected export control evasion activity. The alert also provides additional reporting options directly to BIS enforcement authorities.
Curtis will continue to monitor developments in this rapidly changing area.
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.
National Security Law
Jason D. Wright
John Taishu Pitt
+1 202 452 7373
+1 212 696 6000
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