The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 17 Jan 2025 (BIS):
The Akin Summary document has now been posted for this action.
As part of a coordinated enforcement effort, the Department of Commerce's Bureau of Industry and Security ("BIS") and the Department of the Treasury's Office of Foreign Assets Control ("OFAC") imposed approximately $2.5 million in combined civil penalties against Haas Automation, Inc. ("Haas") for alleged and apparent violations of U.S. export controls and sanctions laws, including illegal shipments of Computer Numerical Control ("CNC") machine parts to Entity-Listed parties in Russia and China.
- 15 Jan 2025 (OFAC):
The Akin Summary document has now been posted for this action.
The U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") designated 16 individuals and 152 entities, and the U.S. Department of State designated more than 150 individuals and entities. The designations (which include many companies, especially in the PRC, that facilitate Russian evasion of U.S. sanctions) were done pursuant to Russia-related Executive Order ("E.O.") 14024 and, in some cases, E.O. 13662 (for which the lifting of sanctions implicates the congressional review provisions of the Countering America's Adversaries Through Sanctions Act ("CAATSA")).
OFAC's designations include entities associated with a Regional Clearing Platform (RCP) sanctions evasion scheme in Russia and the PRC. Additionally, they target Keremet Bank, a bank based in Kyrgyzstan that has facilitated sanctions evasion by Promsvyazbank Public Joint Stock Company (PSB), a previously sanctioned Russian bank that finances Russia's defense industry. It also includes the re-designation of almost 100 previously designated entities under E.O. 13662, focused on entities that facilitate Russian connections with international financing in the energy and weapons industries.
The Department of State sanctions also focus on companies outside of Russia that facilitate Russian sanctions evasion, particularly entities in the PRC. The Department of State is also sanctioning certain subsidiaries of State Atomic Energy Corporation Rosatom.
Concurrent with these designations, OFAC issued three new Russia-related General Licenses ("GLs"):
- GL 122 authorizes wind-down transactions involving certain newly blocked entities;
- GL 123 authorizes transactions necessary to divest from debt or equity guaranteed by Wafangdian Bearing Company Limited, an entity blocked today; and
- GL 26A authorizes transactions with certain blocked individuals that are otherwise prohibited by E.O. 13662.
The OverRuled: China Trade Controls Resource Center has been updated with the following actions:
- 04 Feb 2025 (China - Measures and Countermeasures):
The Ministry of Commerce and the General Administration of Customs jointly issued an announcement to impose export controls on certain items related to tungsten, tellurium, bismuth, molybdenum, and indium. The controls took effect on February 4, 2024.
- 04 Feb 2025 (China - Measures and Countermeasures):
The Ministry of Commerce added PVH Group and Illumina, Inc. to the Unreliable Entity List, for having violated the principle of normal market transactions by cutting normal transactions with Chinese enterprises and adopting discriminatory measures against Chinese firms.
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