New Updates for 17-Jan-2025

2025-01-17

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The OverRuled: Sanctions Module has been updated with the following actions:

  • 16 Jan 2025 - Family International Realty LLC and One Individual - USD $1,076,923

    Between 2018 and 2023, Family International Realty LLC and its owner engaged in a willful scheme to evade OFAC sanctions by concealing the property interest of two sanctioned Russian oligarchs in luxury condominiums and profiting from the rental and sale of the properties.

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

  • 14 Jan 2025 (UK):

    The Akin Summary document has now been posted for this action.

    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.

  • 10 Jan 2025 (UK):

    The Akin Summary document has now been posted for this action.

    ​The Office of Financial Sanctions Implementation ("OFSI") amended UK General Licence INT/2024/4888228 (the "GL"), which clarifies that Statutory Auditors may receive Permitted Payments (both terms as defined therein) made by UK designated persons ("UK DPs") or persons acting on behalf of UK DPs.

  • 10 Jan 2025 (UK):

    The Akin Summary document has now been posted for this action.

    The Office of Financial Sanctions Implementation ("OFSI") designated two entities under the Russia sanctions regime, pursuant to the Russia (Sanctions) (EU Exit) Regulations 2019.

  • 10 Jan 2025 (UK):

    The Akin Summary document has now been posted for this action.

    The Office of Financial Sanctions Implementation ("OFSI") issued General Licence INT/2025/5635701 (the "GL"), pursuant to the Russia (Sanctions) (EU Exit) Regulation 2019. The GL allows for a wind-down period of positions involving Gazprom Neft and PJSC Surgutneftegas (the "DPs"), or any entity owned or controlled, directly or indirectly, by the DPs ("Subsidiary").

  • 10 Jan 2025 (UK):

    The Akin Summary document has now been posted for this action.

    The Office of Financial Sanctions Implementation ("OFSI") issued General Licence INT/2025/5635700 (the "GL") in respect of continued business operations with Gazpromneft-Sakhalin LLC and any entity owned or controlled, directly or indirectly, by Gazpromneft-Sakhalin LLC (together, the "Relevant Subsidiary"), to the extent such operations are related to the projects listed in Schedule 1 of the GL (the "Exempt Projects").

  • 08 Jan 2025 (UK):

    The Akin Summary document has now been posted for this action.

    The Office of Financial Sanctions Implementation ("OFSI") amended UK General Licence INT/2022/1280876 (the "GL") by adding Permission 5.3A. The amended GL prohibits distributions being made on any claims by VTB Bank PJSC ("VTB") or a Transferee (as defined therein) under the GL without first deducting the value of any assets of VTB Capital plc, which have been or are subject to enforcement action by VTB, and the VTB Group Receivables (as defined therein).

  • 07 Jan 2025 (UK):

    The Akin Summary document has now been posted for this action.

    ​The Office of Trade Sanctions Implementation ("OTSI") issued new guidance for UK exporters in respect of countering Russian sanctions evasion (the "Guidance"). The Guidance seeks to support UK exporters in understanding circumvention practices, identifying red flags, utilizing screening tools, and reducing the risk of business being targeted by those seeking to circumvent sanctions measures.

  • 07 Jan 2025 (UK):

    The Akin Summary document has now been posted for this action.

    The Office of Trade Sanctions Implementation ("OTSI") issued new guidance to assist exporters who wish to insert a "no re-export to Russia" clause into their contracts to prevent buyers from re-exporting goods to Russia. The OTSI guidance is aimed at those involved in exporting Common High Priority Items ("CHPI") and any other items critical to Russian weapons systems and military development.

Please send an email to subscriptions@overruled.com if you would like information on how to subscribe to access additional detail about these and other sanctions- and export controls-related actions. If you are already a paid subscriber, please login to OverRuled for access to exclusive content, analysis, and historic search functionality.

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