New Updates for 16-Mar-2023

​Content provided in collaboration with Sayenko Kharenko.

Under the Decree of the President of Ukraine “On Decision of the National Security and Defence Council of Ukraine of 10 March 2023 “On Application of and Amending Personal Special Economic Sanctions and Other Restrictive Measures (Sanctions)” No. 145/2023, dated 10 March 2023, different sanctions were applied to 120 individuals and 287 legal entities somehow related to gambling, betting and lotteries.

​​Content provided in collaboration with​ McCarthy Tétrault​.

Canada prohibits the import of aluminum and steel products originating from Russia.

​"Personal sanctions” are imposed on 144 citizens of Latvia, Lithuania, and Estonia. 

​In a coordinated enforcement action through the Justice Department’s Task Force KleptoCapture, the DOJ, FBI, and BIS jointly announced that the United States obtained a seizure warrant for one Boeing 737-7JU aircraft valued at over $25 million owned by PJSC Rosneft Oil Company, a Russian integrated energy company headquartered in Moscow, Russia.  The warrant is based on probable cause of violations of U.S. export control laws.  

​BIS added two aircraft to its list of commercial and private aircraft that are allegedly in violation of U.S. export controls for entering Russia and/or Belarus without required authorization.

​The Department of Justice ("DOJ") unsealed a 13-count indictment charging two U.S. citizens, Cyril Gregory Buyanovsky and Douglas Edward Robertson, along with KanRus Trading Company, Inc. (“KanRus”), an entity owned and operated by Buyanovsky and Roberston, and which is registered in Kansas, with illegal exports of aviation-related technology from the United States to Russia.

The Akin Summary document has now been posted for this action.

​On February 25, 2023, the European Council published its 10th round of sanctions including, inter alia, a total of 121 new designations (87 individuals and 34 entities), and several products which are now the subject of export controls and enhanced reporting obligations. The export restrictions target electronic components used in Russian weapons systems (including drones, missiles, helicopters and other vehicles), as well as specific rare earths and thermal cameras with military applications. The new reporting obligations require EU persons to retroactively provide information regarding asset transfers of designated person assets prior to their designation, and require private aircraft operators to notify their national authority in advance of any flights between the EU and Russia.

The Akin Summary document has now been posted for this action.

​On February 24, 2023, marking the one-year anniversary of Russia’s invasion of Ukraine, the UK Foreign, Commonwealth and Development Office has added 80 individuals and 12 entities to the Russia sanctions list for the purposes of an asset freeze. Those listed include four Russian elites with close ties to Vladimir Putin, five Iranian senior executives in Qods Aviation Industry Company, and senior executives at Russian state-owned firms Rosatom and Rostec, who are alleged to be involved in helping Russia to maintain its invasion of Ukraine by supplying arms manufacturers with arms exports, technology, and materials to resupply its military-industrial complex.

The UK has also targeted four financial institutions to further isolate Russia from the international system and help the UK and its partners to prevent sanctions circumvention.

The Akin Summary document has now been posted for this action.

​BIS added 86 entities located in Canada, China, France, Luxembourg, Netherlands, and Russia to the Entity List for their alleged support for Russia's military.

The Akin Summary document has now been posted for this action.

​BIS imposed new export control measures on Iran to address the use of Iranian Unmanned Aerial Vehicles (UAVs) by Russia in its ongoing war against Ukraine, contrary to U.S. national security and foreign policy interests.  These controls target Iran’s supply of UAVs to Russia to enhance Russia’s defense industrial base and its military efforts against Ukraine and build on prior amendments to the Export Administration Regulations (EAR), including the addition of Iranian entities to the Entity List as Russian ‘military end users.’

The Akin Summary document has now been posted for this action.

​BIS issued a Final Rule that expanded the scope of the sanctions against Russia and Belarus by adding more items subject to controls for export, reexport, or transfer to or within Russia and Belarus; added Taiwan to the list of countries excluded from certain license requirements on exports to Russia, Belarus, and Iran; and made various other conforming changes and clarifications to the EAR.

The Akin Summary document has now been posted for this action.

​On February 24, 2023, the Secretary of the Treasury issued a “determination” pursuant to section 1(a)(i) of Executive Order (“E.O.”) 14024 authorizing the imposition of sanctions on persons determined to operate or have operated in the “metals and mining” sector of the Russian Federation economy. Concurrent with this determination, OFAC issued certain FAQs clarifying the scope of the new designation authority, namely FAQs 1114, 1115, 1116, and 1117.

The Akin Summary document has now been posted for this action.

​On February 24, 2023, OFAC designated a number of Russian financial institutions and wealth management-related entities, including Credit Bank of Moscow Public Joint Stock Company, one of Russia’s ten largest banks by asset value. OFAC also designated a number of Russian and non-Russian individuals and entities involved in the circumvention of U.S. sanctions and export controls, as well as a number of Russian and non-Russian individuals and entities that are involved in the production of carbon fiber and advanced materials; operate in the Russian aerospace, technology, and defense and related materiel sectors; and a Russian mercenary force operating in Ukraine. OFAC also designated four entities for operating or having operated in the “metals and mining” sector of the Russian Federation economy. In total, OFAC designated 22 individuals and 83 entities.

The U.S. Department of State designated a number of entities and individuals, including a number of Russian governors and government officials, as well as entities and individuals operating or having operated in Russia’s financial services, defense and related materiel, advanced technology, and technology sectors. The Department of State also designated, among others, individuals and entities involved in Russia’s future energy production and three subsidiaries of State Atomic Energy Corporation Rosatom’s civil nuclear structure, and identified 22 vessels as blocked property. The Department of State also announced steps to impose visa restrictions on 1,219 members of Russia’s military for actions that threaten or violate the sovereignty, territorial integrity, or political independence of Ukraine, and also imposed visa sanctions on three Russian Federation military officials under Section 7031(c) of the Department of State, Foreign Operations, and Related Programs Appropriations Act, 2023. In total, the Department of State designated 76 individuals and 52 entities.

In connection with these actions, OFAC amended two existing General Licenses (“GLs”), and also issued two new GLs authorizing wind-down and limited continuing activity with certain entities blocked on February 24, 2023.

The Akin Summary document has now been posted for this action.

​BIS imposed a Temporary Denial Order (“TDO”) on Russian company Radiotester OOO a/k/a Radiotester LLC, and on Russian individual Ilya Balakaev. In parallel, the Department of Justice unsealed a 5-count charging Balakaev for export violations.