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Russia

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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…

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…