The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 15 Jan 2025 (OFAC):
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.
- 14 Jan 2025 (UK):
The Office of Financial Sanctions Implementation ("OFSI") issued General Licence INT/2025/5632740 (the "GL") to facilitate the making available of certain funds to support the basic needs of UK designated persons ("UK DPs") following designation.
The OverRuled: China Trade Controls Resource Center has been updated with the following actions:
- 15 Jan 2025 (BIS):
BIS added 16 entities to the Entity List, including 14 under the destination of the PRC, for the following reasons:
- Supporting or directly contributing to the development of advanced computing integrated circuits (ICs) that further China's development of advanced weapons systems, weapons of mass destruction, and high-tech surveillance applications.
- Supplying Chinese public security end users and posing a risk of diversion to Huawei.
- 15 Jan 2025 (BIS):
BIS added 11 entities to the Entity List under the destination of the PRC for the following reasons:
- Advancing the PRC's military modernization through the development and integration of advanced artificial intelligence research.
- Co-developing lithography technology for advanced-node fabrication facilities in the PRC, enabling indigenous production of advanced integrated circuits (ICs) for military end-use.
- Advancing the PRC's military modernization through the development and integration of advanced artificial intelligence research.
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