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As the political unrest in Ukraine continues, the US Government recently expanded sanctions and export controls targeting the Russian energy, financial, and defense sectors, as follows:
• On September 12, 2014, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) (i) designated five Russian defense companies as Specially Designated Nationals (“SDNs”) and (ii) broadened the scope of US “sectoral” sanctions under Executive Order 13662 to cover the Russian defense sector and additional parties and activities in the Russian energy and financial sectors.
• On September 17, 2014, the US Commerce Department’s Bureau of Industry and Security (“BIS”) published a notice in the Federal Register to (i) implement new restrictions on the export, reexport and transfer of items subject to the Export Administration Regulations (“EAR”) to certain major Russian energy and defense sector companies by adding those companies to the EAR’s Entity List and (ii) impose licensing requirements on the export, reexport, and transfer of certain EAR items for “military end uses” or “military end users” in Russia.
These measures expand upon US sanctions and export control restrictions imposed on Russian and Ukrainian parties, particularly focused on Russia’s energy sector, as described in recent posts on Baker & McKenzie’s Sanctions Update blog and our previous client alerts listed at the end of this alert. Details about these recent measures follow.
Click here to read to full client alert.
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