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US imposes additional sanctions on Russian oligarchs, government officials, and entities

By 5 Mins Read

On April 6, 2018, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced new sanctions measures designating as Specially Designated Nationals (“SDNs“) seven Russian oligarchs and 17 Russian government officials previously identified in a report issued pursuant to Section 241 of the Countering America’s Adversaries Through Sanctions Act (“CAATSA“; see our previous blog post on this report here) under the authority of Executive Orders 13661 and 13662, pertaining to destabilizing activities by Russia in Ukraine. 

BIS revises Entity List to add 15 South Sudanese parties following imposition of arms embargo against South Sudan

By 3 Mins Read

On March 22, 2018, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule [Docket No. 180227219-8219-01] (the “Final Rule”) adding, in relevant part, 15 South Sudanese entities to the Export Administration Regulations’ (“EAR”) Entity List — a step that increases the pressure on that country following the US Government’s imposition of an arms embargo last month.

US – President continues national emergencies with respect to Ukraine, Venezuela and Zimbabwe

By 3 Mins Read

On March 5, 2018, the Federal Register published one year extensions to the following national emergencies because actions and policies addressed in the Executive Orders (EO) in which they were original declared or modified continue to pose an unusual and extraordinary threat to the national security and foreign policy of the United States.

US – Update on (sec. 232) national security implications of steel imports and aluminum imports

By 4 Mins Read

As you may recall, early last year, President Trump issued two presidential memoranda instructing the U.S. Commerce Department to initiate an investigation into the national security implications of steel imports and aluminum imports into the United States.  If these so-called “section 232” (section 232 of the Trade Expansion Act of 1962, as amended) investigations determine that steel import and/or aluminum imports “threaten to impair the national security[,]” then the President can impose additional customs duties (among other things) on covered products.

On June 16, 2018, the Secretary of Commerce issued his reports to the President in both matters (unclassified versions of the reports are available here).   In each case, the Department of Commerce concluded that the quantities and circumstances surrounding steel and aluminum imports “threaten to impair the national security,” thereby opening the door to the imposition of import restraints.  Specifically, Commerce’s recommendations are as follows:

EU imposes sanctions on three Russian individuals and three Russian companies in response to the delivery of Siemens’ turbines to Crimea

By 2 Mins Read

The European Union has imposed sanctions on three Russian individuals, including Deputy Energy Minister Andrey Cherezov, and three Russian companies, including two of Siemens’ contracting companies, in response to the delivery of Siemens’ gas turbines to Crimea in violation of EU sanctions.

US – USTR seeks comments and will hold hearing on Russia’s compliance with WTO commitments

By 1 Min Read

On August 4, 2017, the Office of the United States Trade Representative (USTR) published in the Federal Register a notice [Docket Number USTR-2017-0012] announcing that the interagency Trade Policy Staff Committee (TPSC) is seeking comments and will convene a public hearing to assist the Office of the USTR to prepare its annual report to Congress on Russia’s compliance with the commitments made in connection with its accession to the World Trade Organization (WTO).