The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 26 Jul 2024 (EU):
The Akin Summary document has now been posted for this action.
The European Commission ("Commission") updated its Russia sanctions FAQs in respect of export-related restrictions for dual-use goods and advanced technologies. The updated FAQs confirm the countries that are considered as "partner countries" for the purposes of Council Regulation (EU) No. 833/2014 ("Regulation 833") and adds several items to the correlation table for items captured by Annex VII of Regulation 833.
- 26 Jul 2024 (EU):
The Akin Summary document has now been posted for this action.
The European Commission updated its Russia sanctions FAQs in respect of the import, purchase and transfer of listed goods. The updated FAQs provide further clarification regarding the meaning of "partner countries for the importation of iron and steel" pursuant to Article 3g(1)(d) of Council Regulation (EU) No. 833/2014 ("Regulation 833").
- 24 Jul 2024 (UK):
The Akin Summary document has now been posted for this action.
The Office of Financial Sanctions Implementation ("OFSI") amended the expiry date of General Licence INT/2022/1710676 in respect of the continuation of business with Evraz Plc's North American subsidiaries.
- 24 Jul 2024 (EU):
The Akin Summary document has now been posted for this action.
The European Commission (the “Commission”) updated its Russia sanctions FAQs in respect of Central Securities Depositories ("CSD"). The updated FAQs provide further clarification on the following: (i) whether Depositary Receipts ("DRs") of Russian issuers can be converted into the underlying shares; (ii) whether the conversion of DRs is permitted by Article 6(b)5aa of Council Regulation (EU) No. 269/2014; (iii) whether 'free-of-payment' transfers between sub-accounts within the same EU financial institution or CSD are permitted for Russian shares not targeted by EU sanctions; (iv) whether EU persons and entities may transfer or sell DRs with Russian underlying securities on the secondary market without conversion; and (v) whether EU persons and entities can participate in 'asset swap' schemes implemented by Russian Presidential decree 844.
- 24 Jul 2024 (EU):
The Akin Summary document has now been posted for this action.
The European Commission updated its Russia sanctions FAQs relating to Chemicals to, amongst other things, offer further guidance on the interaction between EU sanctions measures under Council Regulation (EU) 269/2014 ("Regulation 269") and Council Regulation (EU) 833/2014 ("Regulation 833") with the REACH regulation.
- 23 Jul 2024 (UK):
The Akin Summary document has now been posted for this action.
The Office of Financial Sanctions Implementation ("OFSI") amended Permission 5.2 of UK General Licence INT/2022/1280876 (the "GL") in respect of Insolvency Proceedings that apply to OWH SE, the EU subsidiary of VTB (formerly known as VTB Bank (Europe) SE). The Permissions at 5.2 of the GL have been extended with reference to the German Stock Corporation Act and Council Regulation (EC) No 2157/2001.
- 23 Jul 2024 (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") issued its Notice of "Reporting Instructions under the Rebuilding Economic Prosperity and Opportunity for Ukrainians Act" (the "Act"). The Instructions require "financial institutions" (as defined in the reporting instructions) to report, "no later than August 2, 2024 or within 10 days of the detection of [covered] assets" and to the extent such assets have not already been reported to OFAC under separate reporting requirements, "(A) Funds and other property of (i) the Central Bank of the Russian Federation, (ii) the Russian National Wealth Fund, or (iii) the Ministry of Finance of the Russian Federation; or (B) any other funds or other property that are owned by the Government of the Russian Federation, including by any subdivision, agency, or instrumentality of that government." This applies only to property "located" at covered financial institutions.
- 19 Jul 2024 (UK):
The Akin Summary document has now been posted for this action.
The Office of Financial Sanctions Implementation ("OFSI") updated its Financial Sanctions FAQs to provide further guidance in respect of trust services sanctions and UK General Licence INT/2024/4919848 ("GL INT/2024/4919848"). The new FAQs clarify the scope of the UK's trust services restrictions pursuant to Regulation 18C of The Russia (Sanctions) (EU Exit) Regulations 2019 ("Russia Regulations"), as well as the application of GL INT/2024/4919848.
- 18 Jul 2024 (UK):
The Akin Summary document has now been posted for this action.
The Foreign, Commonwealth and Development Office ("FCDO") specified 11 vessels forming part of Russia's "shadow fleet" for the purposes of The Russia (Sanctions) (EU Exit) Regulations 2019.
- 17 Jul 2024 (BIS):
The Akin Summary document has now been posted for this action.
Maxim Marchenko, a Russian national residing in Hong Kong, was sentenced to three years in prison pleaded guilty to charges of money laundering and smuggling microelectronics subject to the EAR from the United States to Russia. Marchenko was arrested in September 2023 and pleaded guilty in February 2024.
- 16 Jul 2024 (UK):
The Akin Summary document has now been posted for this action.
The Office of Financial Sanctions Implementation ("OFSI") updated the UK's Financial Sanctions FAQs to provide further clarification on: (i) whether a person can provide professional and business services to persons connected with Russia when operating or managing a trust; and (ii) how the UK's trust services sanctions interact when an asset freeze applies.
- 15 Jul 2024 (EU):
The Akin Summary document has now been posted for this action.
The European Commission ("Commission") updated its EU FAQs in respect of the "No Re-Export to Russia" clause pursuant to Article 12g of Council Regulation (EU) 833/2014 ("Regulation"). The updated FAQs provide clarification on the following the issues: (i) the purpose of Article 12g; (ii) whether Article 12g applies to existing contracts and public contracts; and (iii) the significance of Article 12g for operators based in non-EU countries.
- 12 Jul 2024 (EU):
The Akin Summary document has now been posted for this action.
The European Commission ("Commission") updated its Russia sanctions FAQs in respect of the Ukrainian Oblasts. The FAQs clarify how operators should assess which areas in Donetsk, Kherson, Luhansk, and Zaporizhzhia are subject to EU restrictions.
- 08 Jul 2024 (Switzerland):
The Akin Summary document has now been posted for this action.
The State Secretariat for Economic Affairs ("SECO") designated 71 individuals and 52 entities under its Russia sanctions regime, which follow recent actions taken by the European Union ("EU") as part of its 14th sanctions package targeting Russia.
- 03 Jul 2024 (EU):
The Akin Summary document has now been posted for this action.
The Council of the European Union (the "Council") released its revised update of the EU Best Practices for the effective implementation of restrictive measures ("Best Practices"). The guidance includes significant guidance and updates to the EU "Ownership" and "Control" tests, amongst other updates.
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