The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 01 Nov 2024 (BIS):
The Bureau of Industry and Security (“BIS”) added 44 entities under 46 entries to the Entity List under the destinations of China (11), India (5), Malaysia (2), Russia (13), Singapore (1), and Turkey (14). According to BIS, these entities were designated for shipping or attempting to ship U.S.-origin and U.S.-branded items to Russia in violation of U.S. export controls; for engaging in research, production, or attempted procurement of materials in support of Russia’s chemical and biological warfare program; or for engaging in other activities contrary to U.S. national security and foreign policy interests. Included among these 44 entities are four address-only entries: Address 12, Address 13, Address 14, and Address 15, all under the designation of China. BIS also modified 49 entries under 52 existing entries on the Entity List to add a footnote 3 designation; these entities were listed under the destinations of China (42), India (4), Turkey (2), the U.K. (2), Estonia (1), Finland (1) and the UAE (1).
- 01 Nov 2024 (BIS):
The Bureau of Industry and Security (“BIS”) issued a new final rule (effective November 1, 2024) that amends the Export Administration Regulations (“EAR”) to strengthen existing export control restrictions against Russia and Belarus. The final rule (i) expands the scope of the existing Russian and Belarusian Industry Sector Sanctions to include nine key precursors for riot control agents and chemical weapons; (ii) adjusts certain exclusions, exceptions, and the licensing policy for the official business of diplomatic or consular missions of governments of Country Group A:5 and A:6 destinations that are located in Russia or Belarus; and (iii) clarifies the applicability of license requirements for the Entity List Foreign Direct Product (“FDP”) rules.
- 30 Oct 2024 (OFAC):
The U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") and the U.S. Department of State designated 32 individuals and 365 entities, pursuant to Executive Order ("EO") 14024. The designations target Russia's military-industrial base and sanctions evasion networks, including persons and entities from Russia as well as Belize, Benin, Bulgaria, the British Virgin Islands, Chile, China, Cyprus, Germany, India, Kazakhstan, Kyrgyzstan, Malaysia, Montenegro, Serbia, Singapore, Switzerland, Thailand, Türkiye, the United Arab Emirates, and Uzbekistan.
Concurrent with these designations, OFAC issued Russia-related General Licenses ("GLs") 110, 111, and 112 authorizing, subject to certain conditions, certain activities involving certain entities blocked on October 30, 2024. Additionally, OFAC issued amended GL 25G, which adds certain entities blocked on October 30, 2024 with which certain transactions related to telecommunications and internet-based communications are not authorized under the GL. OFAC also issued amended GL 8K, which extends the authorization of certain transactions related to energy that involve one or more blocked persons that are specifically listed in the GL until 12:01 a.m. Eastern Daylight Time on April 30, 2025.
Lastly, OFAC issued one new FAQ (1198) and amended two existing FAQs (976 and 1040).
- 30 Oct 2024 (Russia - Countermeasures):
Dividends payable by Russian LLCs to its participants who are non-Russian residents from "unfriendly" jurisdictions cannot be set off against payment obligations of such participants to such Russian LLCs without the prior approval by the Russian Government Commission or the Russian Central Bank.
- 29 Oct 2024 (UK):
The Office of Financial Sanctions Implementation ("OFSI") amended General Licence INT/2022/2300292 (the "GL") in respect of Permitted Payments to Energy Companies for gas and electricity supplies.
- 21 Oct 2024 (Norway):
Norway published measures corresponding with the EU's fourteenth sanctions package targeting Russia.
The OverRuled: China Trade Controls Resource Center has been updated with the following actions:
- 30 Oct 2024 (BIS):
BIS added 40 entities under 42 entries to the Entity List, including seven entries under the destination of the PRC, for the following reasons:
- Diverting controlled items, including U.S.-origin and U.S.-branded components, to Russian entities, including sanctioned entities or those linked to the Russian defense industrial base; and
- Acquiring and attempting to acquire U.S.-origin items related to vibration tables that have explicit military applications and subsequently supplying PRC entities on the Entity List.
BIS also added four "address-only" entries in Hong Kong belonging to corporate secretaries. These addresses are associated with significant transshipment of sensitive goods to Russia and a significant number of entities whose activities risk violating the EAR (e.g., associations with SDNs and Entity List parties).
Finally, BIS modified 49 entities under 52 existing entries on the Entity List, including 42 under the destination of the PRC, by adding a footnote 3 designation. These entities were found to pose a significant risk of involvement in the supply or diversion of EAR items to procurement networks for Russia's defense industry or intelligence services.
- Diverting controlled items, including U.S.-origin and U.S.-branded components, to Russian entities, including sanctioned entities or those linked to the Russian defense industrial base; and
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