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US Government to impose possible significant new sanctions on Russia for use of nerve agent in UK

By 5 Mins Read

On August 9, 2018, the US Department of State issued a press release indicating that the US Government will be imposing new sanctions on Russia for the use of a “Novichok” nerve agent in an attempt to assassinate UK citizen Sergei Skripal and his daughter Yulia Skripal, based on its August 6, 2018, determination under the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (“CBW Act”) that the Russian Government has used chemical or biological weapons in violation of international law or has used lethal chemical or biological weapons against its own nationals.  The CBW Act requires the President to impose sanctions on a foreign country with respect to which such a determination has been made.

WTO Members raise concerns over US Section 232 investigation on automobiles and automotive parts

By 3 Mins Read

The WTO announced that Members expressed their concerns over possible measures by the United States regarding extra duties on the import of automobiles, including cars, SUVs, vans, light trucks and automotive parts, at the Council for Trade in Goods (CTG) held on 3 and 4 of July. Over 40 members — including the 28 European Union members — took the floor to warn of the “serious disruption” to world markets and the multilateral trading system that may arise as a result of these potential measures, particularly in light of the large proportion of global trade accounted for by these products. The announcement said:

Russia introduces new counter-sanctions

By 4 Mins Read

On 4 June 2018, President Putin signed the Federal Law “On Measures (Countermeasures) in Response to Unfriendly Actions of the USA and (or) other Foreign States” (“О мерах воздействия (противодействия) на недружественные действия Соединенных Штатов Америки и иных иностранных государств”, Federal Law 127-ФЗ, the “Law on Countersanctions”). The Law on Countersanctions entered into force on the date of its publication (i.e., on 4 June 2018).

Specifically, the Law on Countersanctions includes the following potential countermeasures:

Ukraine imposes new sanctions against Russia

By 3 Mins Read

On 14 May 2018, the President of Ukraine enacted a decision of the Ukrainian National Security and Defense Council (the “NSDC“) imposing new and extending existing sanctions against certain Russian companies and individuals (the “Decision“). [Decree of the President of Ukraine No. 126/2018 dated 14 May 2018 enacting the NSDC’s Resolution dated 2 May 2018 “On Imposition and Cancellation of Personal Special Economic and Other Restrictive Measures (Sanctions)”.]

UK – Commons Foreign Affairs Committee calls for coherent and proactive Russian sanctions strategy

By 2 Mins Read

The UK House of Commons Foreign Affairs Committee (the “Committee”) has recently published the report on Russian corruption in the UK, calling for a coherent and proactive strategy on Russia. In the report “Moscow’s Gold: Russian Corruption in the UK”, it concluded that the UK financial markets are currently used as a loophole for Russian sanctioned companies to gain access to the capital markets and for Russia to raise sovereign financing.

Russia – Further update on Russia’s proposed new counter-sanctions

By 2 Mins Read

Draft Bill on Russian Countermeasures

On May 17, 2018 Draft Bill No. 441399-7 “On Measures (Countermeasures) in Response to Unfriendly Actions of the USA and other Foreign States” (“Draft on Countermeasures“) was approved by the State Duma of the Russian Federation in the second reading. The scope of the proposed countermeasures remained unchanged. For more details, please see our Legal Alert of May 14, 2018.

Russia – Updates on Russia’s proposed new counter-sanctions

By 5 Mins Read

The Russian government is preparing to introduce new counter-measures in response to US and EU sanctions.

Draft Bill on Russian Countermeasures

Last week the State Duma decided to amend Draft Bill No. 441399-7 “On Measures (Countermeasures) in Response to Unfriendly Actions of the USA and (or) other Foreign States” (“Draft on Countermeasures”).

As opposed to the initial version of the Draft on Countermeasures, the new version proposes the following five measures:

US – OFAC amends and reissues General Licenses clarifying and expanding authorizations for transactions related to maintenance, wind down, and divestment activities with certain Russian SDNs

By 5 Mins Read

On May 1, 2018, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued General License 12B (“GL 12B”) and General License 13A (“GL 13A”), replacing and superseding in their entirety General License 12A (“GL 12A”) and General License 13 (“GL 13”), respectively.  These expanded general licenses are intended to relieve some of the challenges faced by US persons, including US financial institutions, in winding down activities with and divesting interests in certain targeted Russian Specially Designated Nationals (“SDNs”).  Please see our prior blog posts concerning (i) the designation of certain Russian oligarchs, government officials, and entities, and the initial issuance of General License 12 and GL 13 here and (ii) the issuance of GL 12A and General License 14 here.  

US – OFAC issues General License authorizing US Persons to engage in transactions related to winding down or maintaining business with RUSAL during extended period

By 3 Mins Read

On April 23, 2018, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued General License No. 14 (“GL 14”) related to United Company RUSAL PLC (“RUSAL”), to supplement and expand an existing authorization under General License No. 12A (“GL 12A”). GL 14 authorizes US persons to engage in specified transactions ordinarily incident and necessary to the maintenance or winding down of operations, contracts, or other agreements that were in effect prior to April 6, 2018, and that involve RUSAL or any entity in which it owns a 50% or greater interest (together, “RUSAL Entities”).  GL 14 is valid until October 23, 2018.  Along with GL 14, OFAC also issued updated FAQs

US to include digital currency addresses on list of sanctioned parties

By 3 Mins Read

The US Government is considering adding digital currency addresses affiliated with individuals and entities identified to the List of Specially Designated Nationals and Blocked Persons (“SDN List”). This would put US persons on notice that doing business with those digital addresses may be prohibited, increasing compliance considerations for businesses delving into the world of virtual currency.