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US – Recent designation of Russian Federal Security Service under Executive Order 13382 creates disclosure issues for certain issuers in the United States

By 3 Mins Read

Under the Russian encryption regulations, notification to, or registration with, the Russian Federal Security Service (the FSB) is required in order to import and distribute foreign products (hardware and software) with encryption functions or features in the Russian Federation. Although the FSB is a sanctioned party, listed on the Office of Foreign Assets Control (OFAC) list of specially designated nationals and blocked persons (the “OFAC SDN List”) pursuant to the Cyber-Related Sanctions Regulations, 31 C.F.R.…

Ukraine introduces new import ban on a wide range of products originating from Russia

By 1 Min Read

On 13 April 2021, a new import ban will come into effect on 24 new categories of products originating from the Russian Federation. The Cabinet of Ministers of Ukraine adopted a resolution amending the list of products prohibited for import into Ukraine from the Russian Federation, which was previously approved by its Resolution No. 1147 dated 30 December 2015 “On Banning the Import of Products Originating in the Russian Federation into the Customs Territory of…

US – BIS and DDTC implement strengthened US Export Controls on Russia in response to poisoning and imprisonment of Navalny

By , and 3 Mins Read

On March 18, 2021, the US State Department (State) published a Federal Register notice that formally outlines the various US export controls targeting Russia that will be strengthened pursuant to the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (CBW Act) as a result of State’s determination that the Russian Government had used a chemical weapon against its own nationals in violation of international law. These measures were previously announced by State and were summarized…

Ukraine imposes a new set of anti-Russian sanctions

By 3 Mins Read

On 23 March 2021, the president of Ukraine enacted Presidential Decree No. 109/2021 dated 23 March 2021 “On the Decision of the National Security and Defense Council of Ukraine dated 23 March 2021 On Imposition, Cancellation and Amendment of Personal Special Economic and Other Restrictive Measures (Sanctions),” effective from 25 March 2021 (“Sanctions Decision”) imposing personal special economic and other restrictive measures (sanctions) against almost 80 Russian companies, 23 Russian individuals and three Members of…

G7 Statement commits to continued Russia sanctions over Crimea

By 1 Min Read

In an 18 March 2021 statement released by the German Foreign Ministry, the Group of Seven (G7) nations have announced that they remain fully committed to the implementation of sanctions on Russia over the annexation of the Crimean Peninsula. The group’s Foreign Ministers also reaffirmed their unwavering support for and commitment to the independence, sovereignty and territorial integrity of Ukraine, and denounced

US Government imposes new sanctions and export controls on Russia in response to poisoning and imprisonment of Navalny

By , , and 10 Mins Read

On March 2, 2021, the US Government imposed a series of new measures against Russian Government officials and entities in response to the alleged poisoning and subsequent imprisonment of Russian opposition politician Aleksey Navalny. Specifically, the US State Department (State) imposed a number of financial sanctions and export restrictions on Russia; the Office of Foreign Assets Control (OFAC) within the US Treasury Department designated seven Russian officials to the List of Specially Designated Nationals and…

Ukraine – Sanctions for doing business in the Crimea and occupied territories in the East of Ukraine

By 2 Mins Read

On 19 February 2021, Ukraine imposed via Presidential Decree No. 64/2021 dated 19 February 2021 “On the Decision of the National Security and Defense Council “On Imposition and Amendment of Personal Special Economic and other Restrictive Measures (Sanctions)” (the “Sanctions Decision”) personal sanctions against a number of companies and individuals doing business in the Crimea and on the occupied territories of Donetsk and Luhansk regions (“Temporary Occupied Territories”) and suspected of terrorism financing, as well…

US – BIS amends the EAR to enhance certain end-use and end-user controls as well as controls on certain activities of US Persons

By , and 7 Mins Read

On January 15, 2021, the Commerce Department’s Bureau of Industry and Security (BIS) published an interim final rule (“Rule”) amending various provisions of the Export Administration Regulations (EAR) to implement certain provisions of the Export Control Reform Act of 2018 (ECRA).  Among other things further outlined below, the Rule imposes new restrictions on specific activities of US persons. By way of brief background, the EAR generally controls transactions involving US origin items (i.e., goods, software, technology) regardless of whether…

Ukraine imposes a new set of personal sanctions

By 3 Mins Read

Between 28 January and 2 February 2021, the president of Ukraine enacted three decisions of the National Security and Defense Council of Ukraine: Presidential Decree No. 29/2021 dated 28 January 2021 “On the Decision of the National Security and Defense Council of Ukraine dated 28 January 2021 “On Amending the Decision of the National Security and Defense Council of Ukraine dated 14 December 2020 enacted by Presidential Decree No. 564-27т dated 14 December 2020,”” effective from…

US – Commerce publishes interim final rule on Securing the Information and Communications Technology and Services Supply Chain; Comments due March 22, 2021

By , and 6 Mins Read

On January 19, 2021, the Commerce Department published an interim final rule to implement President Trump’s 2019 Executive Order 13873 on “Securing the Information and Communications Technology and Services Supply Chain” (“Interim Rule”). The Interim Rule was issued following the closure of the public comment period on January 10, 2021 on the proposed rules issued on November 27, 2019 (“Proposed Rules”) to implement Executive Order 13873. For more information on Executive Order 13873 and the Proposed Rules, please see our blog…