New Updates for 15-Jul-2024

2024-07-15

Reading Time : 8 min

The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:

11 Jul 2024 (Russia - Countermeasures):
The Russian President introduced temporary management in the Russian subsidiaries of Silgan Holdings.
10 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 General License ("GL") 13J, which extends the authorization of certain administrative transactions prohibited by Directive 4 under E.O. 14024, until 12:01 a.m. Eastern Daylight Time on October 9, 2024.
04 Jul 2024 (Russia - Countermeasures):
Russia suspends its participation in the work of the OSCE Parliamentary Assembly.
03 Jul 2024 (Russia - Countermeasures):
The Russian Central Bank clarified the process of returning clearing collateral by clearing organizations to foreign creditors.
03 Jul 2024 (UK):
The Akin Summary document has now been posted for this action.
The Office of Financial Sanctions Implementation ("OFSI") issued UK General Licence INT/2024/4919848 (the “GL”), which allows the sale, divestment, and transfer of financial instruments held by the National Settlement Depository ("NSD") and the payment of safe keeping fees.
03 Jul 2024 (UK):
The Akin Summary document has now been posted for this action.
The Office of Financial Sanctions Implementation ("OFSI") issued General Licence INT/2024/4907888 (the "GL") in respect of payments by UK designated person(s) ("UK DP" or "UK DPs"), or Persons acting on their behalf (as defined under the GL), which allows for payments to Visa Application Services Providers (as defined under the GL), from a UK DP or on behalf of a UK DP. The GL applies to all sanctions regulations made under the Sanctions and Anti-Money Laundering Act 2018 (the Sanctions Act), as listed in Annex I of the GL (the "UK Autonomous Sanctions Regulations").
02 Jul 2024 (EU):
The Akin Summary document has now been posted for this action.
The European Commission published new FAQs concerning the restrictive measures under Article 3s of Council Regulation (EU) No. 833/2014 (the "Regulation") which apply to targeted vessels listed in Annex XLII (the "Targeted Vessels"). FAQ 1 clarifies whether Targeted Vessels laden with dangerous or polluting goods, such as oil, at the date of targeting can access EU ports and services to unload its cargo.
02 Jul 2024 (EU):
The Akin Summary document has now been posted for this action.
The European Commission published updated FAQs relating to State-Owned Enterprises to clarify the transaction ban imposed against Sovcomflot pursuant to Article 5aa of Council Regulation (EU) No. 833/2014 ("Regulation 833").
02 Jul 2024 (EU):
The Akin Summary document has now been posted for this action.
The European Commission published updated FAQs relating to the provision of restricted services under Article 5n of Council Regulation (EU) No. 833/2014 (the "Regulation"). FAQs, 16, 17, 18 and 19 (inclusive) provide further clarification regarding which Russian subsidiaries fall within the exemption provided by Article 5n(7) of the Regulation, and whether those entities must be exclusively or indirectly owned by, or solely or jointly controlled by, a citizen, legal person, entity or body incorporated in an EU Member State, the EEA, Switzerland or a partner country specified in Annex VIII.
02 Jul 2024 (EU):
The Akin Summary document has now been posted for this action.
The European Commission published updated EU FAQs in respect of divestment from Russia to clarify why the derogations under Article 12b(1) and (2) of Council Regulation (EU) No. 833/2014 (the "Regulation") were introduced. FAQ 1 reaffirms that EU operators divesting from Russia remain bound by the prohibitions specified in the Regulation. EU operators are therefore prohibited from importing goods subject to an import prohibition from Russia into the Union or to sell, transfer or supply prohibited goods falling to a Russian buyer. According to the European Commission, the derogations provided by Article 12b(1) and (2) of the Regulation have been introduced as a temporary measure to enable operators to facilitate an expeditious exit from the Russian market.
02 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 "General Questions" relating to Russia sanctions under Council Regulation (EU) 269/2014 ("Regulation 269") and Council Regulation (EU) 833/2014 ("Regulation 833"). The EU FAQs confirm the relationship between the prohibitions in Regulation 269 and Regulation 833, as well as clarify whether an entity subject to an EU asset freeze under Regulation 269, and the prohibitions under Regulation 833, can still benefit from a derogation or exemption provided by Regulation 833.
01 Jul 2024 (UK):
The Akin Summary document has now been posted for this action.
The Office of Financial Sanctions Implementation ("OFSI") issued General Licence INT/2024/4881897 (the "GL") in respect of payments by UK designated persons ("UK DPs"), or Persons acting on behalf of UK DPs, to make Permitted Payments to the Revenue Authorities.
29 Jun 2024 (EU):
The Akin Summary document has now been posted for this action.
The Council of the European Union (the "Council") imposed new sanctions measures against Belarus in view of the regime's continued support for Russia's war of aggression against Ukraine.
The restrictive measures seek to mirror those currently imposed against Russia and target various sectors of the Belarusian economy, including trade, certain professional services and transport, to limit Belarus' industrial capacity. The new sanctions package introduces broader export controls on dual-use items and advanced technologies, including maritime navigation and luxury goods, and on goods and technologies suitable for use in oil refining and the liquefaction of natural gas. The EU has also prohibited the import of gold, diamonds, helium, coal and mineral products and crude oil, which have allowed Belarus to diversify its sources of revenue.
To reduce the risk of circumvention in respect of sensitive goods, the Council requires EU exporters to include in their future contracts a "no export to Belarus clause", which contractually prohibits the re-exportation to Belarus, or re-exportation for use in Belarus, of certain sensitive items. EU operators trading in such items to third countries must implement due diligence mechanisms capable of identifying, assessing, and mitigating the risks of re-exportation to Belarus.
In addition, EU operators are now required to undertake their 'best efforts' to prevent third-country subsidiaries from engaging in any activities that undermine EU sanctions against Belarus.
28 Jun 2024 (EU):
The Akin Summary document has now been posted for this action.
The Council of the European Union (the "Council") designated two individuals and four entities for actions undermining or threatening the territorial integrity, sovereignty, and independence of Ukraine. Among those targeted include Dmitry Beloglazov, Mikhail Kontserev, LLC Titul, JSC Iliadis, Rasperia, and PJSC TransContainer. These entities/individuals have been identified for: (i) engaging in complex EU sanctions circumvention schemes, which have benefitted persons subject to an EU asset freeze, such as Oleg Deripaska, by assisting designated persons to acquire assets in violation of EU sanctions; and (ii) supporting the Russian Government through illegal weapon trade schemes.
28 Jun 2024 (UK):
The Akin Summary document has now been posted for this action.
The Office of Financial Sanctions Implementation ("OFSI") updated UK General Licence INT/2022/2470156 (the "GL") to extend the expiration date applicable to Schedule 1 Exempt Projects, by one year until June 28, 2025.
27 Jun 2024 (UK):
The Akin Summary document has now been posted for this action.
The Office of Financial Sanctions Implementation ("OFSI") issued General Licence INT/2024/4888228 (the "GL") under all UK Autonomous Sanctions Regulations (as listed in Annex 1 of the GL). Subject to complying with the relevant conditions, the new GL allows UK designated persons ("DPs"), or Persons acting on behalf of a UK DP, to make Permitted Payments to Statutory Auditors for the purposes of conducting a Statutory Audit.
26 Jun 2024 (OFAC):
The Akin Summary document has now been posted for this action.
OFAC issued amended General License ("GL") 55B, which authorizes certain services related to the maritime transport of crude oil originating from the Sakhalin-2 project, extending the authorization under such GL until 12:01 a.m. Eastern Daylight Time on June 28, 2025.
24 Jun 2024 (EU):
The Akin Summary document has now been posted for this action.
The Council of the European Union (the "Council") confirmed that the restrictive measures referred to in Article 2f of Regulation (EU) No 833/2014 shall apply to all entities listed in the Annex to Regulation (EU) 2024/1428, as of June 25, 2024, including:
- Voice of Europe;
- Ria Novosti;
- Izvestija; and
- Rossiiskaja Gazeta.
24 Jun 2024 (EU):
The Akin Summary document has now been posted for this action.
The European Union ("EU") adopted its 14th package of sanctions against Russia. The new sanctions package introduces, inter alia, enhanced anti-circumvention measures, additional asset freeze restrictions, new designations against 27 vessels for the purposes of an EU port access ban and related services, amendments to sectoral and trade sanctions targeting high-value sectors of the Russian economy, including energy, finance, and transport. Several existing exemptions and derogations were also extended or amended.
Among the implemented measures, a broad new requirement has been introduced for EU parent companies to undertake their 'best efforts' to ensure that their third-country subsidiaries do not take part in any activities resulting in an outcome that the sanctions seek to prevent. The EU's 14th sanctions package has also imposed restrictions on Russian liquefied natural gas ("LNG") projects, as well as a new prohibition on transshipment operations and reloading in the Union where those services are used to transship Russian LNG.
To further limit Russia's ability to wage its war in Ukraine, the EU has taken steps to ban the use of Russia's SPFS financial messaging system by EU entities operating outside of Russia, along with imposing new restrictions on the registration of intellectual property rights and transfer of industrial know-how outside the Union relating to Common High Priority items.
21 Jun 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") designated 12 individuals in executive and senior leadership roles at AO Kaspersky Lab ("Kaspersky Lab"), pursuant to E.O. 14024, for operating or having operated in the technology sector of the Russian Federation economy. According to OFAC, these actions were taken to ensure the integrity of the U.S. cyber domain and to protect against malicious cyber threats. These designations follow actions by the Department of Commerce targeting Kaspersky Lab-related entities. Notably, OFAC did not designate Kaspersky Lab, its parent or subsidiary companies, or its CEO.

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