The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 01 May 2024 (OFAC):
The U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") and the U.S. Department of State concurrently designated over 280 individuals and entities, and identified 16 vessels as blocked property (the "Blocked Vessels"), pursuant to Executive Order ("E.O.") 14024 and E.O. 13382. The designations target Russia's military-industrial base and chemical and biological weapons programs, as well as companies and individuals in third countries, such as Azerbaijan, Belgium, China, Russia, Slovakia, Türkiye, and the United Arab Emirates, that help Russia evade and circumvent sanctions to acquire key inputs for weapons or defense-related production intended to further its war in Ukraine.
Concurrent with these designations, OFAC issued General License ("GL") 95, GL 96, and GL 97, all of which authorize, subject to certain conditions, certain activities involving certain persons and vessels blocked on May 1, 2024.
Concurrent with these designation actions, the U.S. Department of State also delivered to Congress a determination pursuant to the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 regarding Russia's use of the chemical weapon chloropicrin against Ukrainian troops, which re-imposes restrictions on foreign military financing, U.S. Government lines of credit, and certain export licenses for defense articles and national security-sensitive items going to Russia.
- 01 May 2024 (OFAC):
The Department of Justice ("DOJ"), in coordination with the DOJ Task Force KleptoCapture, filed a forfeiture complaint today against a set of aircraft landing gear for a Boeing 737-800 that was detained in September 2023 by U.S. Customs and Border Patrol ("CBP"). The gear was allegedly purchased by an intermediary in Istanbul, GQ Solutions Elektronik Ekipman Limited Sirketi, for the benefit of a Kyrgyz Republic-based transhipper of dual-use items servicing Russia in connection with a previously U.S.-designated entity, LLC RM Design and Development ("RMDD"), in violation of U.S. sanctions. Concurrent with this forfeiture action, the U.S. Department of State announced new sanctions against entities for operating or having operated in the technology sector of the Russian Federation, including GQ Solution Elektronik Ekipman Limited Sirketi in connection with the company's supplying of electronic components to Russia-based companies.
- 24 Apr 2024 (OFAC):
President Biden signed into law a wide-ranging legislative package of which Sec. 2 of Division F is the "REPO for Ukrainians Act" ("REPO Act"). This statute provides a mechanism for the eventual transfer of "Russian sovereign assets or any funds or property" for the "purpose of providing assistance to Ukraine for the damage resulting from the unlawful invasion by the Russian Federation that began on February 24, 2022". In the short term, the REPO Act prohibits OFAC from licensing the transfer or release of "funds and other property" that are "effectively immobilized" as a result of the non-blocking Directive 4 Issued Under E.O. 14024, as well as blocked funds of "the Government of the Russian Federation, including by any subdivision, agency, or instrumentality of that government".
The OverRuled: China Trade Controls Resource Center has been updated with the following actions:
- 01 May 2024 (OFAC):
The United States sanctioned more than 280 individuals and entities, targeting Russia's military-industrial base and chemical and biological weapons programs as well as companies and individuals in third countries that help Russia acquire key inputs for weapons or defense-related production.
In this action, OFAC designated nearly 200 entities and individuals located in Azerbaijan, Belgium, the PRC, Russia, Slovakia, Türkiye, and the United Arab Emirates for: enabling Russia to acquire desperately-needed technology and equipment from abroad; operating or having operated in the technology, defense and related materiel, manufacturing, or transportation sectors of the Russian Federation economy; supplying cotton cellulose and its highly flammable byproduct, nitrocellulose, to Russia; procuring items for military institutes involved in Russia's chemical and biological weapons programs; or operating or having operated in the construction sector of the Russian Federation economy.
The following Hong Kong and PRC-based entities are sanctioned pursuant to EO 14024:
- Tulun International Holding Limited;
- RG Solutions Limited;
- Finder Technology Limited;
- Juhang Aviation Technology Shenzhen Co, Ltd.;
- Wuhan Global Sensor Technology Co., Ltd.;
- Wuhan Tongsheng Technology Co., Ltd.;
- HK Hengbangwei Electronics Limited;
- Chip Space Electronics Co., Limited;
- IPM Limited;
- Chengdu Keylink Wireless Technology Co., Ltd;
- Jinmingsheng Technology HK Co Limited;
- Zhongcheng Heavy Equipment Defense Technology (Shandong) Group Co., Ltd;
- Shvabe Opto-Electronics Co., Ltd;
- Pixel Devices Limited;
- Hengshui Heshuo Cellulose Co., Ltd.; and
- Hengshui Yuanchem Trading Limited
The Department of State concurrently designated more than 80 entities and individuals based in Russia, Singapore, Hong Kong, Türkiye, the Kyrgyz Republic, and Malaysia pursuant to EO 14024. These targets are engaged in: development of Russia's future energy, metals, and mining production and export capacity; sanctions evasion and circumvention; and furthering Russia's ability to wage its war against Ukraine.
The listed Hong Kong and PRC-based entities are:
- CFU Shipping Co Limited;
- Silver Technology Limited;
- Mornsun Guangzhou Science and Technology Co Ltd;
- Yantai Iray Technology Co Ltd;
- Anyang Forging Press Numerical Control Equipment Co Ltd; and
- Chongqing Zongshen Aero Engine Manufacturing Co Ltd
The vessels Hunter Star and Nan Feng Zhi Xing are being identified as property in which CFU Shipping Co Limited has an interest.
- Tulun International Holding Limited;
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