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Russia

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On July 28, 2020, Draft Bill No. 996800 was introduced in the State Duma of Russia proposing additional Russian countersanctions (“Draft“). The Draft proposes to introduce amendments to the Federal law No. 281-FZ dated December 30, 2006 “On special economic measures and coercive actions” that sets forth the legal framework for the Russian countersanctions regime. The Draft proposes the following principal provisions: Application of the restrictive measures to the entities controlled by the sanctioned persons. These controlled…

On July 15, 2020, the US Department of State (State Department) updated its guidance (“Updated Guidance“) regarding the implementation of Section 232 of Title II of the Countering America’s Adversaries Through Sanctions Act (“CAATSA” see our previous blog post on CAATSA here and our previous blog post on the 2017 State Department guidance on CAATSA Section 232 here). The Updated Guidance expands the scope of CAATSA Section 232 to target certain investments or other activities related to the Nord Stream…

On Monday 6 July 2020, the UK introduced the first sanctions under its new Global Human Rights sanctions regime, targeting 47 individuals and 2 entities. The regulations setting out the sanctions are made under the Sanctions and Anti-Money Laundering Act 2018 (the “Sanctions Act“) and impose asset freezes and travel bans on individuals and entities responsible for or involved in serious violations of human rights. The Sanctions Act was introduced to allow the UK to…

On May 28, 2020, the Federation Council of Russia received the Draft Bill proposing additional Russian countersanctions (“Draft“) that was approved by Russian State Duma in the second and the third readings on May 27, 2020. This Draft passed the first reading in Russian State Duma on July 24, 2019 (see our post on this here). The Draft has been amended since then and now proposes the following principal provisions: Unless otherwise set forth under the…

On April 28, 2020, the Department of Commerce’s Bureau of Industry and Security (BIS) published two new final rules and a proposed rule in the Federal Register amending the Export Administration Regulations (EAR) to tighten restrictions on exports of technology to China, Russia, and Venezuela. According to Commerce Secretary Wilbur Ross, these actions are intended to combat efforts by entities in China, Russia, and Venezuela to use certain US technologies obtained through civilian supply chains…

In response to the growing impact of the COVID-19 Coronavirus in Europe, a number of countries have implemented national controls to restrict the export of medicines and medical equipment, such as face masks, gloves, and protective clothing. Over the weekend, the EU Commission reviewed actions taken by Member States and, while it has discouraged Member States from adopting measures which would limit intra-EU trade, it has introduced a temporary export ban on exports of certain…

On February 18, 2019, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), pursuant to Executive Order (“EO”) 13850, designated Rosneft Trading S.A., the Swiss-incorporated, Russian-controlled oil brokerage firm, as a Specially Designated National (“SDN”) for operating in the oil sector of the Venezuelan economy. OFAC also designated the President and Chairman of Rosneft Trading S.A., Didier Casimiro, as an SDN for purporting to act for or on behalf of, directly or…

On 16 December 2019, the Russian Government signed Resolution No. 1685, which expanded an import ban with respect to Ukrainian goods. The list of banned goods initially introduced by Resolution of the Russian Government No. 1716-83 dated 29 December 2018 now includes cornstarch, glucose and fructose, a number of medical goods (such as medical stoppers, hot-water bags, ball syringes), radiators, central-heating boilers and waste paper. These goods are prohibited from entering Russia if they (i) originate from Ukraine, (ii) are supplied from Ukraine, or (iii) have…

On 27 September 2019, theFederal Council announced the opening of consultation proceedings on amendments to the Embargo Act. The changes are intended to ensure that the ban on imports of firearms, weapon components, ammunition and other goods from Russia and Ukraine can continue. In addition, the Federal Council will no longer have to rely on provisions of the Federal Constitution in order to deal with similar cases. According to the announcement: The Ordinance on Measures…

In a notification published in the Federal Register on August 26, 2019, the State Department provided additional information on restrictions on exports to Russia that were initially described by Secretary of State Mike Pompeo on August 2, 2019 when he announced the second round of targeted sanctions on Russia under the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (the “CBW Act”). Our blog post on the August 2, 2019 announcement (“Announcement”), which described…