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Russia

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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…

On August 15, 2019 the Russian President issued Decree No. 388, establishing a special record-keeping regime for ownership rights over the securities of particular issuers. According to Decree No. 388, if a person who holds more than 1% of the issuer’s voting shares requests information about other shareholders from the registrar, the registrar provides such information excluding the information on sanctioned Russian shareholders, if any.  This would apply only if the issuer has notified the…

The UK government has introduced a new national control on the export of submersible vessels and related equipment, software and technology to Russia, which enters into force on 14 August 2019. The additional control has been introduced for reasons of national security and as a result of Russia developing its capabilities to track, access and disrupt undersea communication cables. Exporters may apply for export licences for controlled items, which will be assessed on a case-by-case…

On August 14, 2019, the US Trade Representative (USTR) published in the Federal Register a notice of public hearing and request for comments [Docket No. USTR-2019-0011] regarding Russia’s compliance with its World Trade Organization (WTO) commitments. The interagency Trade Policy Staff Committee (TPSC) invites interested persons to submit written comments and participate in a public hearing to assist the Office of the USTR in the preparation of its annual report to the Congress on Russia’s…

On August 2, 2019, the US State Department announced targeted sanctions against Russia related to the March 2018 use of a “novichok” nerve agent in an attempt to assassinate UK citizen Sergei Skripal and his daughter Yulia Skripal in the United Kingdom.  This was the second round of sanctions required under the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (the “CBW Act”) following the State Department’s determination on November 6, 2018 that Russia…

The Russian State Duma is considering amendments to Federal Law “On Measures (Countermeasures) in Response to Unfriendly Actions of the USA and (or) other Foreign States” (“Law on Countersanctions“) dated June 4, 2018. On July 24, 2019, Draft Bill proposing additional Russian countersanctions (“Draft“) was approved by the Russian State Duma in the first reading. The amendments to the Draft will be presented till August 22, 2019. The second reading of the Draft has not…

On June 20, 2019, the Russian Prime Minister signed Resolution No. 787-31, introducing changes to Governmental Decree No. 1716-83 dated December 29, 2018 that implemented an import ban with respect to Ukrainian goods (please refer to our previous blog posts of January 18, 2019 and April 23, 2019). Per the changes adopted by Resolution No. 787-31: 1) The import ban does not apply to goods imported to complete customs procedures for processing outside the customs territory and temporary…

President Hassan Rouhani has announced that Iran will withdraw from certain commitments agreed in the 2015 nuclear agreement; this announcement comes a year after the agreement was abandoned by the US, leading to the re-imposition of US sanctions against Iran. In his 8 May 2019 announcement, Hassan Rouhani declared that Iran will stop exporting its surplus enriched uranium. This decision is contrary to the agreement, under which Iran is required to sell its surplus enriched…

On April 30, 2019, the Department of Defense, Defense Acquisition Regulations System, published in the Federal Register an interim rule [Docket DARS-2019-0016] amending the Defense Federal Acquisition Regulation Supplement (DFARS) to implement a section of the National Defense Authorization Act for Fiscal Year 2019 that prohibits acquisition of certain magnets and tungsten from North Korea, China, Russia, and Iran.