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Ukraine Crisis – US Sanctions Update

UPDATE:

Week of October 24, 2022

  • Treasury Department Sanctions Moldovan Entities for Supporting Russia’s Global Influence Campaign: On October 26, the Treasury Department’s Office of Foreign Assets Control (OFAC) took action to counter the Russian government’s persistent malign influence campaigns and systemic corruption in Moldova by imposing sanctions on nine individuals and 12 entities. Those designated include oligarchs who have corrupted Moldova’s political and economic institutions and who have acted as instruments of Russia’s global influence campaign. Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson stated “The sanctions imposed today expose not only Russia’s covert strategy in Moldova, but also demonstrate how corruption undermines the rule of law.” (https://home.treasury.gov/news/press-releases/jy1049)
  • House Speaker Pelosi Rejects GOP Suggestion that US Aid to Ukraine is a ‘Blank Check’:While attending the First Parliamentary Summit of the International Crimea Platform on October 24, Speaker of the House Nancy Pelosi pushed back against the Republican Party’s suggestion that the US has given a “blank check” of humanitarian and military aid to Ukraine. Speaker Pelosi stated that the support for Ukraine is “bipartisan, bicameral and it starts in the White House with our President.” This comes following House Minority Leader Kevin McCarthy’s comments that if the Republicans win the House in the midterm elections, they would cut back aid to Ukraine. Speaker Pelosi also said Iran is making “a big mistake” by assisting Russia in its war against Ukraine. (https://www.washingtonpost.com/politics/2022/10/24/pelosi-ukraine-elections-russia/)
  • US State Department Meets with Domestic Diamond Industry to Discuss Russian Sanctions: The US State Department announced on October 25 that the Department’s Head of the Office of Sanctions Coordination, Ambassador James O’Brien, led an interagency discussion with the U.S. offices of leading diamond retailers, manufacturers, and laboratories. The meeting focused on the importance of the diamond industry’s robust implementation of Russia-focused sanctions and broader due diligence standards. (https://www.state.gov/state-department-meets-with-u-s-diamond-industry-to-discuss-sanctions/)
  • US Shows Concern over Russian-Iranian Cooperation: During an October 26 Press Briefing by US Press Secretary Karine Jean-Pierre and National Security Council Coordinator for Strategic Communications John Kirby, Ms. Jean-Pierre shared the US government’s concern that “Moscow may be advising Tehran on best practices to manage protests, drawing on Russia’s extensive experience in suppressing open demonstrations” while “Iran is helping Russia wage its war against Ukraine.” Mr. Kirby added that “it’s just yet another example of Russia and Iran now working together to violate the — not only the human rights and civil rights of people in Iran, but, of course, put in further danger the lives of Ukrainians.”(https://www.whitehouse.gov/briefing-room/press-briefings/2022/10/26/press-briefing-by-press-secretary-karine-jean-pierre-and-national-security-council-coordinator-for-strategic-communications-john-kirby-3/)
  • US Press Secretary Answers Questions on Russian-Iranian Sanctions and Starlink: During an October 21 press gaggle, White House Press Secretary Karine Jean-Pierre was asked what US would do to match the EU’s sanctions on Iran for supplying the Russian military with drones, and whether the US is considering starting a procurement process for Ukraine’s internet services following Elon Musk’s public withdrawal of his request for Pentagon funding of Starlink. Regarding the Iran issue, Press Secretary Jean-Pierre reiterated the Biden administration’s continued enforcement of all existing sanctions on both Russian and Iranian arms trade, making it harder for Iran to sell these weapons to Russia, and “help the Ukrainians have what they need to defend against these threats”. She has nothing specific to share in relation to Starlink or procurement for Ukraine’s internet services. (https://www.whitehouse.gov/briefing-room/press-briefings/2022/10/21/press-gaggle-by-press-secretary-karine-jean-pierre-en-route-dover-delaware/)
  • Treasury Secretary Discusses Oil Price Cap at SIFMA’s Annual Meeting: On October 24, Secretary of the Treasury Janet L. Yellen spoke at the Securities Industry and Financial Markets Association’s Annual Meeting. Among other things, Secretary Yellen discussed the supply chain vulnerabilities exposed by Russia’s invasion of Ukraine and the US’ partnership with G7 to finalize and implement a cap on the price of Russian oil. “The goal of this cap is to keep Russian oil flowing onto global markets — at lower prices — while reducing revenue that Putin can use to fund his illegal war. This effort will help stabilize energy markets. It will also provide developing countries with greater leverage to negotiate better prices for Russian oil.”(https://home.treasury.gov/news/press-releases/jy1045)
  • Repatriation of U.S. Citizen Remains from Ukraine: On October 26, the US Department of State expresses condolences to the families of the US citizen killed in the fighting in Ukraine and appreciation to Ukraine for including recovery of this individual’s remains in its negotiations with Russia. The Department of State once again reiterated that US citizens should refrain from travelling to Ukraine, the risks of participating in the fight in Ukraine and other opportunities to help Ukraine and its people. (https://www.state.gov/repatriation-of-u-s-citizen-remains-from-ukraine/)

UPDATE:

Week of October 10, 2022

  • DOJ Arrests UK Businessman for Sanctions Evasion: On October 11, the Department of Justice announced the arrest of Graham Bonham Carter, a UK businessman that served as Oleg Deripaska’s property manager, for conspiracy to violate US sanctions and wire fraud. Deripaska, who is subject to US sanctions, was previously charged with sanctions violations in a September 29 indictment. According to the Department’s press release, Bonham Carter allegedly engaged in over $1 million in illicit real estate transactions for Deripaska’s benefit. (https://www.justice.gov/opa/pr/uk-businessman-graham-bonham-carter-indicted-sanctions-evasion-benefitting-russian-oligarch).
  •  US Considering Ban on Russian Aluminum: On October 12, Bloomberg reported that the US is considering a ban on imports of Russian aluminum. This restriction could come in the form of an outright ban, extremely punitive tariffs on Russian aluminum, or sanctions on Russia’s major aluminum producer, Rusal. Russian aluminum has avoided US import bans thus far, as it is a critical component in multiple industries. (https://www.bloomberg.com/news/articles/2022-10-12/white-house-weighs-ban-on-russian-aluminum-in-retaliatory-move).
  • Treasury to Host International Officials to Discuss Restrictions on Russian Defense Supply Base: On October 14, the Treasury Department is planning to host officials from 30 countries to discuss the Biden administration’s efforts to cut off Russia’s military industrial complex supply chains. Deputy Treasury Secretary Wally Adeyemo, Deputy Commerce Secretary Don Graves and Deputy Director of National Intelligence Morgan Muir will host the meeting. (https://www.cnn.com/2022/10/07/politics/us-russian-defense-supply-chain-crackdown/index.html).
  • Treasury Department Official Optimistic About Efficacy of Oil Price Cap: Speaking at Columbia University on October 12, Deputy Treasury Secretary Wally Adeyemo said that the Department is optimistic that an oil price cap would create “economic incentives … that will allow oil to flow and bring down the costs…. for buyers, but also bring down revenues for Russia.” Adeyemo added that the Department is working on finalizing the details of the price cap. He did not expect that the Department would need to impose secondary sanctions for its Russia sanctions program to be effective. (https://www.reuters.com/markets/commodities/treasurys-adeyemo-counting-russian-oil-price-cap-not-secondary-sanctions-2022-10-12/).
  • Treasury Department Previews Future Assistance: At the Treasury Department’s Second Ministerial Roundtable Discussion for Support to Ukraine on October 12, Treasury Secretary Janet Yellen urged donors to “keep stepping up” their economic assistance to Ukraine. She noted the recently passed $4.5 billion in grant assistance for Ukraine, and added “with our price cap on Russian oil, we are targeting Russia’s key source of revenue while stabilizing global energy markets.” (https://home.treasury.gov/news/press-releases/jy1014).
  • Presidents Biden and Zelenskyy Speak: On October 10, President Biden and Ukrainian President Volodymyr Zelenskyy spoke by telephone. According to a readout of the call, President Biden expressed condolences for lives lost in overnight shelling in Ukraine, and “underscored his ongoing engagement with allies and partners to continue imposing costs on Russia.” (https://www.whitehouse.gov/briefing-room/statements-releases/2022/10/10/readout-of-president-joe-bidens-call-with-president-volodymyr-zelenskyy-of-ukraine/).
  • US Criticizes Hong Kong for Hosting Oligarch’s Yacht: After news broke that a yacht linked to sanctioned oligarch Alexey Mordashov was docked in a Hong Kong harbor, a State Department spokesman said in an emailed statement to Bloomberg that “the possible use of Hong Kong as a safe haven by individuals evading sanctions from multiple jurisdictions further calls into question the transparency of the business environment.” (https://www.bloomberg.com/news/articles/2022-10-10/us-warns-hong-kong-to-not-be-haven-for-sanctioned-russians).
  • State Department Condemns Russian Missile Strikes: On October 10, the State Department released a statement condemning Russian airstrikes against civilian targets in Ukraine. The statement called on the international community to condemn the attacks, and reiterated that the US will “continue to provide vital economic, humanitarian, and security assistance so Ukraine can defend itself and take care of its people.” Secretary of State Antony Blinken also called Ukrainian Foreign Minister Dmytro Kuleba to express his condolences for civilian lives lost in the missile strikes. (https://www.state.gov/u-s-support-for-ukraine-in-the-face-of-russian-strikes/; https://www.state.gov/secretary-blinkens-call-with-ukrainian-foreign-minister-kuleba-31/).

UPDATE:

Week of September 26, 2022

  • OFAC Designates New Persons in Response to Referenda in Ukraine: On Friday, the Treasury Department’s Office of Foreign Asset Control designated 14 persons in Russia’s military-industrial complex, including two international suppliers, three key leaders of Russia’s financial infrastructure, immediate family members of some of senior Russian officials, and 278 members of Russia’s legislature for enabling Russia’s sham referenda and attempt to annex sovereign Ukrainian territory. The designated individuals were added to the Specially Designated Nationals list. The Department issued these restrictions in response to Russian-led referendums in eastern Ukraine; in announcing the sanctions, Treasury Secretary Janet Yellen said, “We will not stand by as Putin fraudulently attempts to annex parts of Ukraine. The Treasury Department and U.S. government are taking sweeping action today to further weaken Russia’s already degraded military industrial complex and undermine its ability to wage its illegal war.” (https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220930).

  • New OFAC FAQ Warns of Increased Secondary Sanctions Risk: In addition to the new designations, OFAC released a new FAQ on Friday warning that the US “is prepared to more aggressively use its authorities under existing U.S. sanctions programs to target such persons whose activities may constitute material assistance, sponsorship, financial, material, or technological support for, or goods or services to, or in support of (together “material support”), sanctioned persons or sanctionable activity,” even if these individuals are not US persons. The FAQ lists activity of particular focus, including providing support for Russian-led referenda in eastern Ukraine, providing support to the Russian military and defense industrial base, attempting to circumvent US sanctions on Russia and Belarus, and providing support to Russian entities or individuals subject to blocking sanctions. (https://home.treasury.gov/policy-issues/financial-sanctions/faqs/1091)

  • BIS Adds 57 to the Entity List: The Department of Commerce’s Bureau of Industry and Security also issued a new rule adding 57 entities located in Russia and the Crimea region of Ukraine to the Entity List for supporting the Russian invasion of Ukraine. Under Secretary of Commerce for Industry and Security Alan Estevez confirmed that this addition was done in response to the Russian referenda in eastern Ukraine. (https://www.bis.doc.gov/index.php/documents/about-bis/newsroom/press-releases/3146-2022-09-30-bis-press-release-bis-adds-57-to-entity-list-final/file).

  • BIS FAQ Clarifies Future Designations in Third Countries: In addition to the new additions to the entity list, BIS published an FAQ discussing the Bureau’s ability and willingness to impose export control restrictions on companies or government entities in third countries (outside of Russia or Belarus) that support the Russian and Belarusian military. The FAQ states, “The Department of Commerce is prepared to aggressively apply export controls imposed in response to Russia’s war of aggression against Ukraine against any entities, both inside and outside of Russia, that seek to provide material support for Russia and Belarus’s military and industrial sectors, including to replenish (“backfill”) technologies and other items prohibited by the United States and the 37 allies and partners that have implemented substantially similar controls.” (https://www.bis.doc.gov/index.php/documents/about-bis/3145-2022-09-30-bis-faq-third-country-application-of-controls/file).

  • State Department Expands Visa Restrictions:Joining other sanctioning authorities, the State Department imposed visa restrictions on 910 individuals in response to Russian-organized referenda in Ukraine. The restrictions include members of the Russian Federation military, Belarusian military officials, and Russia’s proxies for violating Ukraine’s sovereignty, territorial integrity, and political independence. The State Department also designated Russian national, Ochur-Suge Mongush, for his involvement in a gross violation of human rights perpetrated against a Ukrainian prisoner of war. Under this authority, Mongush and his immediate family members are ineligible for entry into the United States. (https://www.state.gov/imposing-swift-and-severe-costs-in-response-to-russias-violations-of-ukraines-sovereignty/).

  • DOJ Issues Indictment for Deripaska and Associates for Sanctions Evasion: On September 29, the Department of Justice unsealed an indictment charging Oleg Deripaska, Natalya Mikhaylovna Bardakova, and Olga Shriki for conspiring to violate US sanctions imposed on Deripaska and one of his corporate entities, Basic Element Limited. Shriki was also charged with obstruction of justice based on her alleged deletion of electronic records relating to her participation in Deripaska’s sanctions evasion scheme following receipt of a grand jury subpoena. In addition, Ekaterina Olegovna Voronina was charged with making false statements to agents of the U.S. Department of Homeland Security at the time of Voronina’s attempted entry into the United States for the purpose of giving birth to Deripaska’s child. (https://www.justice.gov/opa/pr/russian-oligarch-oleg-vladimirovich-deripaska-and-associates-indicted-sanctions-evasion-and).
  • Administration Officials Say More Sanctions Coming: In a Senate Foreign Relations Committee hearing on September 28, Biden administration officials in charge of sanctions policy told lawmakers that new sanctions on Russia in response to the country’s referendums in eastern Ukraine would focus on  revenue from Russia’s oil and gas sales and access to global supply networks to replenish the Russian military. They added that the administration is working to improve coordination between allies on the issue. Senators at the hearing were concerned that the sanctions were not putting enough pressure on Russia. (https://apnews.com/article/russia-ukraine-putin-technology-jeanne-shaheen-886000f537aee2c6069f608b5401a1ec).
  • Administration Hesitant to Impose Secondary Sanctions on Non-G7 Countries Regarding Oil Price Cap: The Wall Street Journal reported on September 26 that administration officials are pushing back on a bipartisan Senate proposal that would impose secondary sanctions on entities located outside of the G7 countries that avoid the G7’s oil price cap, set to be in place later this year. Experts believe that this legislation would suppress the Russian oil supply in the market, and draw significant opposition from Europe. (https://www.wsj.com/articles/biden-administration-resists-call-to-broaden-plan-for-russia-oil-price-cap-11664136499).
  • BIS Adds Another Iranian Plane to Export Control List for Aiding Russia: On September 26, the Department of Commerce’s Bureau of Industry and Security announced that it had added an Iranian owned and operated aircraft providing cargo flight services on US origin aircraft to Russia in violation of US export controls. It is the fourth Iranian aircraft added to the Department’s list of sanctioned aircraft, which now numbers at 184. The plane is owned by Saha Airlines, which itself is owned and operated by the Iranian Air Force. (https://bis.doc.gov/index.php/documents/about-bis/newsroom/press-releases/3143-2022-09-26-bis-press-release-additional-iranian-gp10-aircraft/file).
  • Delaware Blocking Startups with Russian Ties: The Wall Street Journal reported on September 29 that the Delaware Division of Corporations has told “dozens” of technology ventures incorporated in the state that they can no longer do business in Delaware after a review of their corporate filings showed that they contain individuals or business addresses located in Russia. The affected startups still exist as Delaware corporations, but may not make corporate filings or pay taxes to the state. Delaware is a major corporate hub. (https://www.wsj.com/articles/delaware-freezes-out-russia-linked-startups-extending-sanctions-reach-11664449203).
  • New Budget Legislation Contains $12 Billion in Assistance for Ukraine: On September 29, the Senate passed a funding bill that includes $12.3 billion in new military and economic assistance to Ukraine. The bill authorizes the President to direct the drawdown of up to $3.7 billion for the transfer of excess US weapons stocks to Ukraine, and includes $35 million to prepare for nuclear threats in Ukraine. (https://www.reuters.com/world/us/us-stopgap-funding-bill-heading-possible-thursday-passage-senate-2022-09-29/).
  • State Department Commits $457.5 Million in Civilian Security Assistance to Ukraine: On September 26, the State Department announced that it had committed an additional $457.5 million in civilian security assistance to Ukrainian law enforcement and criminal justice agencies. The Department has provided over $645 million in such assistance since mid-December 2021. (https://www.state.gov/457-5-million-in-new-u-s-civilian-security-assistance-for-ukraine/).
  • White House Ready to Impose “Severe Economic Consequences” if Russia Annexes Parts of Ukraine: In her September 23 press briefing, White House Press Secretary Karine Jean Pierre provided the White House’s response to Russia’s referendums in eastern Ukraine. She said the United States was “prepared to impose additional swift and severe economic costs on Russia, along with our allies and partners, in response to these actions if they move forward with annexation.” (https://www.whitehouse.gov/briefing-room/press-briefings/2022/09/23/press-briefing-by-press-secretary-karine-jean-pierre-september-23-2022/).
  • White House Threatens “Catastrophic Consequences” if Russia Uses Nuclear Weapons in Ukraine: Speaking on various talk shows on September 25, National Security Advisor Jake Sullivan said that the administration has told Russia that it will face “catastrophic consequences” if it uses a nuclear weapon in Ukraine. In speeches last week, Russian President Vladimir Putin hinted that the use of nuclear weapons was possible in the country’s conflict with Ukraine. (https://www.marketwatch.com/story/u-s-warns-russia-of-catastrophic-consequences-if-it-uses-nukes-in-ukraine-11664141192?mod=mw_latestnews).
  • Google Says Russia Teaming Up with Hacker Groups: On September 23, The Wall Street Journal reported that Mandiant, Google’s cybersecurity arm, has observed increasing cooperation between the Russian government and hacking groups since the start of the invasion of Ukraine. The attacks have targeted US government installations. (https://www.wsj.com/articles/google-sees-russia-coordinating-with-hackers-in-cyberattacks-tied-to-ukraine-war-11663930801).

UPDATE:

Week of September 19, 2022

  • President Biden Discusses China’s Role in Russia-Ukraine Conflict: In a Sunday (September 18) interview on 60 Minutes, President Biden said that he has told Chinese President Xi Jinping that it would be a “tremendous mistake” to violate sanctions imposed on Russia. He noted that the call was not intended to threaten China. He added, “Thus far, there’s no indication they’ve [China has] put forward weapons or other things that Russia has wanted.” (https://thehill.com/policy/international/3649531-biden-says-he-warned-xi-that-breaking-russia-sanctions-would-be-gigantic-mistake/).
  • Senators Introduce Legislation to Impose Secondary Sanctions to Facilitate Price Cap: Senators Chris Van Hollen (D-MD) and Pat Toomey (R-PA) introduced legislation that would impose secondary sanctions necessary to impose a price cap on Russian oil. The legislation would target financial institutions involved in trade finance, insurance, reinsurance, and brokerage of Russian oil and petroleum products sold at prices above the cap. (https://www.reuters.com/world/us-senators-want-secondary-sanctions-russian-oil-2022-09-20/).
  • US Officials Express Frustration Over Sanctions Impact: On Friday (September 16), CNN reported that anonymous US officials are frustrated over what they see as a relatively limited impact of sanctions on the Russian economy. One of the officials was quoted as saying, “We were expecting that things like SWIFT and all the blocking sanctions on Russia’s banks would totally crater the Russian economy and that basically, by now going into September, we’d be dealing with an economically much more weakened Russia than the one that we are dealing with.” The officials acknowledged that they expected the sanctions to be in place for the mid-to long-term. (https://www.cnn.com/2022/09/16/politics/russia-sanctions-ukraine-slow-economic-pain/index.html).
  • President Biden Discusses Response to Russian Invasion of Ukraine in UNGA Address: On September 21, President Biden delivered an address to the UN General Assembly (“UNGA”). The remarks criticized Russia for violating the UN Charter in invading Ukraine, and discussed efforts with allies to “impose costs” on Russia. President Biden also announced an additional $2.9 billion in humanitarian and food security assistance, in part to respond to food supply chain disruptions brought on by the war in Ukraine. He also emphasized that US sanctions do not impact food and fertilizer exports, saying “It’s Russia’s war that is worsening food insecurity, and only Russia can end it.” (https://www.whitehouse.gov/briefing-room/speeches-remarks/2022/09/21/remarks-by-president-biden-before-the-77th-session-of-the-united-nations-general-assembly/).
  • Secretary of State Addresses UNSC, Praises Unity Against Russia: On September 22, Secretary of State Antony Blinken addressed the United Nations Security Council (UNSC). Though he did not mention sanctions specifically, he praised the “more than 40 nations have come together to help the Ukrainian people defend themselves, a right that is enshrined in Article 51 of the United Nations Charter.” His remarks criticized President Putin’s continued aggression in Ukraine, including the threat of nuclear weapons, and called on the rest of the world to address food security issues stemming from the conflict in Ukraine. (https://www.state.gov/secretary-antony-j-blinken-at-the-united-nations-security-council-ministerial-meeting-on-ukrainian-sovereignty-and-russian-accountability/).

UPDATE:

Week of September 12, 2022

  • OFAC Adds Names to Entity List, Expands Restricted Activity: On September 15, the Department of the Treasury’s Office of Foreign Asset Control (OFAC) announced several new actions related to Russia (https://home.treasury.gov/news/press-releases/jy0954):
  • Additional SDN Designations: OFAC designated an additional 22 persons and 2 entities that are supporting Russia’s invasion of Ukraine. The designations add their names to the Specially Designated Nationals list.
  • New General License: General License 51 permits transactions ordinarily incident and necessary to the wind down of any transaction involving Limited Liability Company Group of Companies Akvarius, or any entity owned 50 percent or more by Akvarius, through 12:01am eastern on October 15, 2022. (https://home.treasury.gov/system/files/126/russia_gl51.pdf).
  • Restrictions on Quantum Computing Services: OFAC also issued a determination under Executive Order 14071 that prohibits US persons from exporting, reexporting, selling or supplying, directly or indirectly, quantum computing services to any individual located in Russia. OFAC also issued a directive under Executive Order 14024 permitting the imposition of sanctions on any entity in the Russian quantum computing sector.
  • New FAQs: While certain FAQs update information to include new general licenses, others discuss the Russian National Payment Card System (NSPK). The FAQ notes that, while NSPK is not itself a blocked entity, banks could use its MIR payment system to facilitate payments to sanctioned parties. The FAQ warns, “non-U.S. financial institutions that enter into new or expanded agreements with NSPK risk supporting Russia’s efforts to evade U.S. sanctions” and “OFAC is prepared to use these targeting authorities in response to supporters of Russia’s sanctions evasion, including Russia’s efforts to expand the use of NSPK or the MIR National Payment System outside of the territory of the Russian Federation.” (https://home.treasury.gov/policy-issues/financial-sanctions/faqs/added/2022-09-15).
  •  BIS Issues New Export Controls: On September 15, the Department of Commerce Bureau of Industry and Security (BIS) issued new export controls on Russia and Belarus. Among other changes, the rule expands the scope of the Russian industry sector sanctions to new items (including EAR99 items), and expands the rule to cover Belarus, as well as Russia.; broadens the scope of the “military end user” and “military intelligence end user” controls and expand their reach to Belarusian, Burmese, Cambodian, Chinese, Russian, and Venezuelan end users of the relevant category anywhere in the world; designates six entities under ten Entity List entries as Russian military end user; and sets dollar value exclusion thresholds for certain luxury goods restricted for export to Russia. (https://public-inspection.federalregister.gov/2022-19910.pdf).
  • OFAC Issues Guidance on Price Cap for Russian Oil: On September 9, OFAC issued guidance on its price cap for purchasing Russian oil. The cap is structured as a services ban, with an exception for jurisdictions or actors that purchase Russian seaborne oil at or below the yet-to-be-established price cap. The guidance contains documentation requirements for the price cap, dependent on the service provider and the role they play in an oil purchasing transaction, and examples of red flags that should alert service providers that a transaction is evading the price cap. It does not create an exception for the US’s ban on bringing Russian oil to the US. The guidance warns that persons that make significant purchases of Russian oil above the price cap and knowingly rely on providers subject to the policy will be a target of sanctions enforcement. The price cap will enter into effect on December 5, 2022 for crude oil and February 5, 2023 for petroleum products. (https://home.treasury.gov/system/files/126/cap_guidance_20220909.pdf).
  • Senators Introduce Legislation to Declare Russia a State Sponsor of Terrorism: On September 14, Senators Lindsay Graham (R-SC) and Richard Blumenthal (D-CT) introduced legislation that would designate Russia as a state sponsor of terrorism. The legislation would circumvent the State Department, which typically has the authority to make these decisions. The White House publicly opposed the designation last week, with Spokeswoman Karine Jean Pierre saying that the designation would have negative repercussions for aid efforts in Ukraine, among other issues. (https://www.politico.com/newsletters/national-security-daily/2022/09/14/new-senate-bill-ramps-up-fight-over-russia-terrorism-label-00056600).
  • US Welcomes Suspension of Ukrainian Debt: On September 14, Secretary of the Treasury Janet Yellen welcomed the conclusion of the Memorandum of Understanding between the group of creditors of Ukraine and the Ukrainian government to suspend service of Ukrainian debt through the end of 2023. Her statement urged other bilateral creditors and private creditors to provide similar relief. (https://home.treasury.gov/news/press-releases/jy0950).
  • Treasury Secretary Discusses Financial Assistance with Ukrainian PM: On September 9, Treasury Secretary Janet Yellen held a virtual meeting with Ukrainian Prime Minister Denys Shymal. The pair discussed American plans to provide financial assistance to Ukraine, with Secretary Yellen promising $8.5 billion in total aid by the end of September. She also noted that the Biden administration is requesting an additional $4.5 billion in economic assistance for Ukraine in the coming months. They also discussed the price cap on Russian oil. (https://home.treasury.gov/news/press-releases/jy0944).
  • US Expects Russia to Engage in Covert Political Financing Abroad to Advocate for Sanctions Relief: In an interview on September 13, an anonymous intelligence staffer stated that Biden administration expects Russia to engage in covert political financing of far right political parties and think tanks to advocate for sanctions relief abroad. The staffer said, “we are engaging with allies and partners to gather more information about this threat.” (https://www.reuters.com/world/us-says-russia-spent-over-300-million-foreign-influence-efforts-since-2014-2022-09-13/).

UPDATE:

Week of September 5, 2022

  • Treasury Sanctions Iranian Entity Involved in Shipping Weapons to Russia: On September 8, the US Department of the Treasury issued new sanctions on Safiran Airport Services, which, according to the Department, “has coordinated Russian military flights between Iran and Russia, including those associated with transporting Iranian UAVs, personnel, and related equipment from Iran to Russia.” The restrictions will add Safiran Airport Services to the Specially Designated Nationals list. (https://home.treasury.gov/news/press-releases/jy0940).
  • Treasury Issues New Russia General License 13B: On September 8, the Department of the Treasury issued General License 13B, which extends the license allowing US persons to pay taxes, fees, and import duties and to receive permits, licenses, and registrations in Russia through 12:01am Eastern on December 7, 2022. (https://home.treasury.gov/system/files/126/russia_gl13b.pdf).
  • White House Opposes Designating Russia as a State Sponsor of Terrorism: During her daily press briefing on September 6, White House Press Secretary Karine Jean Pierre stated that President Biden had decided to not designate Russia as a state sponsor of terrorism. She said that the “designation could have unintended consequences to Ukraine and the world,” including in the realm of humanitarian assistance deliveries. She added that the decision may fracture the global coalition opposing Russia. (https://www.nytimes.com/2022/09/07/world/europe/biden-will-not-designate-russia-a-state-sponsor-of-terrorism.html).
  • Treasury Secretary Welcomes Price Cap Agreement for Russian Oil: On September 2, Treasury Secretary Janet Yellen released a statement praising the G7 for agreeing to implement a price cap on Russian oil. She described the price cap as “one of the most powerful tools we have to fight inflation and protect workers and businesses in the United States and globally from future price spikes caused by global disruptions.” She noted that the agreement had already had impacts on Russian behavior, highlighting recent Russian negotiations for oil trades at steep discounts. (https://home.treasury.gov/news/press-releases/jy0936).
  • Biden Administration Requests $11.7 Billion in Additional Assistance for Ukraine: On Friday (September 2), the Biden administration provided an emergency funding request to Congress. The proposed spending package includes $11.7 billion in additional assistance for Ukraine. Administration officials said that this funding would supplement the already-passed $40 billion aid package for Ukraine, saying that 75% of those funds had already been spent. The new money would include funds for equipment, intelligence support, and direct budgetary backing for Ukraine. (https://www.rferl.org/a/biden-emergency-funds-ukraine-11-billion-russia-invasion/32016321.html).
  • US Increases Aluminum, Nickel Imports from Russia in Second Quarter: Reuters reported on September 6 that UN Comtrade data indicates that EU and US imports of aluminum and nickel increased by as much as 70 percent between March and June of this year. In response to the report, a State Department spokesman said, “although we don’t preview our sanctions actions, nothing is off the table to increase the price on Putin’s unjustified war against Ukraine.” (https://www.reuters.com/markets/europe/exclusive-eu-us-step-up-russian-aluminium-nickel-imports-since-ukraine-war-2022-09-06/).
  • Pentagon Preparing Assessment of Long Term Support for Ukraine: On September 7, CNN reported that the Pentagon is preparing a detailed assessment on medium and long term support for Ukraine. Chairman of the Joint Chiefs of Staff Mark Milley is leading efforts in this space. The assessment is intended to review support for the Ukrainian military for five years after the current conflict ends. (https://www.cnn.com/2022/09/07/politics/us-military-ukraine-analysis/index.html).
  • US Announces $2.2 Billion in Additional Military Assistance to Ukraine and its Neighbors: During Secretary of State Antony Blinken’s visit to Ukraine on September 8, he announced that the administration is planning to notify Congress that it intends to make $2.2 billion in Foreign Military Financing available to Ukraine and its neighbors. Ukraine will receive $1 billion of the funds itself. In addition, the Secretary announced that the administration had authorized an additional $675 million in military assistance for Ukraine earlier that day. (https://www.state.gov/secretary-blinken-travels-to-ukraine-and-belgium/; https://www.state.gov/2-8-billion-in-additional-u-s-military-assistance-for-ukraine-and-its-neighbors/).  
  • US Criticizes Russian Decision to Close Nord Stream Pipeline: After Russia’s decision to close the Nord Stream I pipeline on September 2, a National Security Council official emailed Reuters to criticize the decision. The source said, “It is unfortunately not surprising that Russia continues to use energy as a weapon against European consumers.” (https://www.reuters.com/business/energy/russia-using-energy-weapon-white-house-says-about-nord-stream-shutdown-2022-09-02/).
  • State Department Official Rules Out US Visa Ban for Russians: In a September 3 interview with independent Russian media outlet Dozhd, State Department Spokesman John Kirby said that the Department did not support a ban on issuing US visas to Russian citizens, saying, “[w]e do not believe that holding all Russians accountable for Putin’s actions is a productive measure.” (https://kyivindependent.com/uncategorized/white-house-rules-out-complete-visa-ban-for-russians).  
  • However, Russia Highlights Lack of US Visas for UNGA Delegation: On Friday (September 2), the Russian government sent a letter to UN Secretary-General Antonio Guterres indicating that the US had not provided 56 requested visas for Russian officials, including Foreign Minister Sergei Lavrov, to attend the UN General Assembly. The meeting is scheduled to begin on September 15. (https://www.reuters.com/world/russia-says-no-us-visas-yet-lavrov-visit-united-nations-2022-09-02/).

UPDATE:

Week of August 29, 2022

  • Justice Department Obtains Warrant for Seizure of $45 Million Plane Owned by Lukoil: On Wednesday (August 31), the Department of Justice announced that it had received a warrant to seize a Boeing 737-7EM aircraft owned by PJSC Lukoil. The plane allegedly flew in and out of Russia, in violation of US sanctions. The plane is believed to be currently located in Russia. (https://www.justice.gov/opa/pr/united-states-obtains-warrant-seizure-45-million-airplane-owned-russian-energy-company-pjsc).
  • Commerce Department Restricts Sales of AI Chips to Russia: In a Wednesday (August 31) evening filing with the Securities and Exchange Commission, US chip makers Nvidia and AMD reported that the Commerce Department had warned them that Chinese companies would be banned from purchasing high-end integrated circuits intended for use in artificial intelligence applications. The government told Nvidia that the ban would help ensure that Nvidia’s products are not “used in” or “diverted to” Russian or Chinese military equipment, according to Nvidia’s filing. (https://fortune.com/2022/09/01/nvidia-amd-chip-sales-ai-china-russia-military/).
  • Western Allies Expected to Commit to Russian Oil Price Cap on Friday: On Thursday (September 1), The Wall Street Journal reported that finance ministers from the G-7 will meet on Friday to endorse a multilateral effort to set a price cap on Russian oil and commit to finalizing their plans by the end of the year. The Treasury Department has consistently pushed for this policy since spring. (https://www.wsj.com/articles/u-s-allies-prepare-to-outline-plan-to-limit-price-of-russian-oil-11661977820).
  • Exxon Mobil Threatens Suit in Russia Over Sakhalin Project: On Tuesday (August 30), Exxon Mobil said that it had notified Russian officials that it intends to file suit in Russia if the country does not allow it to sell its stake in the Sakhalin-1 oil project. The Russian government has filed decree banning certain transactions through the end of the year, and it has blocked Exxon since early August from transferring operatorship and selling its 30 percent stake in the Sakhalin-1 project. Exxon previously announced that it would be transitioning Russian operations to another party as a result of the invasion of Ukraine. (https://www.wsj.com/articles/exxon-escalates-dispute-with-russia-over-barred-exit-from-giant-oil-project-11661851802).
  • Treasury Secretary “Optimistic” About Progress Toward Oil Price Cap: On Wednesday (August 31), Treasury Secretary Janet Yellen met with UK Chancellor of the Exchequer Nadhim Zahawi during his trip to Washington. In prepared remarks in advance of the meeting, Secretary Yellen stated “I’m really optimistic about the substantial progress that’s been made by our teams and the entire G7 for making the price cap a reality,” and she looked forward to discussing the issue further in their meeting. (https://home.treasury.gov/news/press-releases/jy0932).
  • Senators Portman, Klobuchar Visit President Zelenskyy in Ukraine: On Tuesday (August 30), Senator Rob Portman (R-OH) and Amy Klobuchar (D-MN) met with Ukrainian President Volodymyr Zelenskyy, Ukrainian Defense Minister Oleksii Reznikov and other senior Ukrainian leaders in Kyiv. The group sought to reaffirm the United States’ commitment to Ukraine. After the visit, President Zelenskyy said on Telegram, “the development of the situation at the front was discussed in detail. I am grateful to the United States for the security assistance! It should be continued and increased. This is important for the victory of Ukraine.” (https://thehill.com/homenews/house/3621563-portman-klobuchar-meet-with-zelensky-in-ukraine/). 
  • National Security Advisor Calls for Demilitarized Area Around Zaporizhzhia: On Monday (August 29), National Security Advisor Jake Sullivan told reporters that the White House was calling for Russia to agree to a demilitarized zone around the Zaporizhzhia nuclear plant, administered by the International Atomic Energy Agency. (https://www.reuters.com/world/white-house-calls-demilitarized-zone-around-ukraine-nuclear-plant-2022-08-29/).
  • Dell Ceases Operations in Russia: On Saturday (August 27), Dell Technologies announced that it had closed all its offices in Russia and ceased all operations in the country in mid-August. The company had previously suspended all sales in Russia. (https://www.reuters.com/business/russia-shrugs-off-jobs-impact-after-reports-dell-exiting-country-2022-08-27/).
  • State Department Welcomes Grain Shipments: On August 30, the State Department released a statement welcoming the arrival of theBrave Commander cargo ship, which was carrying 23,300 metric tons of Ukrainian grain, to Djibouti. US funding to the World Food Programme helped facilitate the shipment, and the Department expects more agricultural deliveries from Ukraine to occur in the near future. (https://www.state.gov/arrival-of-wheat-carrying-brave-commander-to-east-africa-from-ukraine/).

UPDATE:

Week of August 22, 2022

UPDATE:

August 08, 2022

  • Reuters Investigation Uncovers US Chips in Russian Missiles: AReuters investigation published on Monday indicates that Russian missiles landing in Ukraine still contain components made in the United States. Many of these items include standard computer processor chips, not the high-tech military equipment subject to US export controls. Several US companies, including Infineon and Texas Instruments, have launched investigations after customs data from distributors indicates that third party sellers are still sending processors to Russia after the start of the war in Ukraine. (https://www.reuters.com/investigates/special-report/ukraine-crisis-russia-missiles-chips/).
  • Senators Call on Biden Administration to Designate Russia as State Sponsor of Terrorism: On CNN on Sunday, Sens. Richard Blumenthal (D-CT) and Lindsay Graham (R-SC) both called for the state sponsor of terrorism designation to be made by either the President or Congress amid Russia’s ongoing war on Ukraine, remaining hopeful that the President would make the decision prior to action by Congress. (https://www.cnn.com/2022/08/07/politics/biden-russia-state-sponsor-of-terrorism-cnntv/index.html).
  • Department of Justice Receives Authority to Seize Sanctioned Oligarch’s Jet: On Monday, the Department of Justice announced that it had received authority from the US District Court for the Southern District of New York to seize an Airbus A319-100 owned and controlled by sanctioned Russian oligarch Andrei Skoch. The jet is believed to be worth more than $90 million. The investigation was conducted through the Department’s Task Force KleptoCapture. (https://www.justice.gov/opa/pr/united-states-obtains-warrant-seizure-airplane-sanctioned-russian-oligarch-andrei-skoch-worth).
  • Secretary of State Blinken Travels to Africa To Limit Russian and Chinese Influence: US Secretary of State Antony Blinken will travel to South Africa, the Democratic Republic of the Congo, and Rwanda this week amid efforts to counter Russian outreach and influence in Africa. (https://www.cnbc.com/2022/08/08/echoes-of-the-cold-war-as-blinken-heads-to-africa-vying-with-russia-for-influence.html).
  • In Africa, US Ambassador to the UN Warns African Countries on Russia Sanctions: On the heels of a recent visit by Russian Foreign Minister Sergey Lavrov to Russia and amid the impacts of rising food prices, US Ambassador to the United Nations Linda Thomas-Greenfield traveled to Uganda and Ghana. In Uganda, she warned against African countries breaking sanctions (including potentially through purchases of Russian oil) through engagement with Russia, except for purchases of Russian agricultural products, including fertilizer and wheat. (https://www.nytimes.com/2022/08/05/world/europe/us-africa-russia-sanctions.html).
  • Defense Department Announces Additional $1 Billion in Ukraine Assistance: On Monday, the Defense Department announced that the President had authorized an additional $1 Billion in military assistance for Ukraine. The package includes additional High Mobility Artillery Rocket System ammunition, artillery ammunition, mortar systems and ammunition, National Advanced Surface to Air Missile systems, Javelin and anti-armor systems, medical treatment vehicles, anti-personnel munitions, and medical supplies. (https://www.defense.gov/News/Releases/Release/Article/3120059/1-billion-in-additional-security-assistance-for-ukraine/).
  • First Shipment of Mars US Sour Crude to Germany Leaves Louisiana: Late last week, a tanker of US sour crude left the port of New Orleans bound for the German port of Rostock. This is the first shipment of Mars US sour crude to Germany ever; a few tankers of West Texas Sour crude shipments have previously been shipped to the country. This demonstrates Germany’s commitment to replace Russian oil imports with oil from other sources. (https://www.reuters.com/business/energy/us-sour-crude-cargo-sails-germany-russia-sanctions-bite-2022-08-08/).
  • Secretary of State Blinken Issues Statement on Anniversary of Russian Invasion of Georgia: On August 7, fourteen years after the Russian invasion of Georgia, US Secretary of State Tony Blinken issues a statement, stating that “This year, Russia’s unprovoked further invasion of Ukraine underscores the need for the people of Georgia and Ukraine to stand together in solidarity.  The people of Georgia know all too well how Russia’s aggressive actions, including disinformation, so-called “borderization,” and mass displacement cause untold hardships and destruction” and committing to ongoing support to the Georgian people. (https://www.state.gov/anniversary-of-the-russian-invasion-of-georgia/).

UPDATE:

August 05, 2022

  • US Official to Warn African Countries of Dangers of Dealing with Russia in Upcoming Trip: In an interview in advance of her upcoming trip to several African countries, US Ambassador to the UN Linda Thomas-Greenfield said that, while she intended the trip to be a “listening tour,” she said that she would warn countries engaging directly with Russia “where there are sanctions, then they are breaking those sanctions.” She emphasized that African nations “can buy Russian agricultural products, including fertilizer and wheat.” (https://www.nytimes.com/2022/08/05/world/europe/us-africa-russia-sanctions.html).
  • In Uganda, US Ambassador to the United Nations Disputes That US Sanctions on Russia Are to Blame for High Food and Commodity Prices: In Kampala, Uganda, US Ambassador to the United Nations Linda Thomas-Greenfield told journalists that it was wrong to blame the US for higher prices, rather than Russia for starting a war in Ukraine. (https://www.independent.co.ug/us-sanctions-on-russia-not-responsible-for-high-commodity-prices/).

UPDATE:

August 04, 2022

  • US Senators Call for Sanctions on Russian Officials that AttackedOpposition Leader Kara-Murza: On Thursday, Senators Marco Rubio (R-FL), Richard Durbin (D-IL), Thom Tillis (R-NC), and Jeanne Shaheen (D-NH) sent a letter to Secretary of State Antony Blinken urging him to impose sanctions under the Magnitsky Act on the Russian government officials that attempted to assassinate Russian opposition leader Vladimir Kara-Murza. (https://www.rubio.senate.gov/public/index.cfm/press-releases?id=FEFA2ECD-C3F6-4846-9DE0-78A2945C927C).

UPDATE:

August 03, 2022

  • State Department Welcomes Shipment of Ukrainian Grain: On Wednesday, Secretary of State Antony Blinken released a statement welcoming the departure of a Ukrainian grain ship from the Black Sea for the first time since February. He also used the statement to call on Russia to “end its attacks that are rendering farmland in Ukraine unusable and destroying agricultural infrastructure. As long as Russia continues its aggression, the Ukrainian people and the world’s most vulnerable will continue to suffer its effects.” (https://www.state.gov/first-grain-ship-departs-the-black-sea/).
  • US-Led Price Cap Faces Resistance from Insurers Abroad: On Wednesday, The New York Times reported that UK and EU-based insurance groups were pushing back on a US-led proposal that would impose a price cap on Russian oil. Insurers, who would need to verify the price at which oil was purchased, are skeptical about the enforceability of the proposal, particularly if only a handful of countries go along with the cap. Nevertheless, the price cap remains an important talking point for Biden administration officials in meetings with their counterparts. (https://www.nytimes.com/2022/08/03/us/politics/us-russia-oil-prices.html).
  • Treasury Department Issues Technical Amendments to August 2 General Licenses: On Wednesday, the Treasury Department issued technical amendments to General Licenses 40A, 47, and 48 to update the name of Joint Stock Company State Transportation Leasing Company. Treasury noted that Tuesday’s issuance of these General Licenses omitted the word “Leasing” from the name. (https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220803).
  • US Senate Moves to Ratify NATO Membership for Sweden and Finland: On Wednesday, the US Senate approved, in a 95-1 vote, approval of a treaty to include Finland and Sweden in NATO. Their admission will require approval by all 30 current NATO members, with 22 members already having done so. (https://www.nytimes.com/2022/08/03/world/europe/sweden-finland-nato-senate-vote.html).

UPDATE:

August 02, 2022

  • State Department Welcomes Shipment of Ukrainian Grain: On Wednesday, Secretary of State Antony Blinken released a statement welcoming the departure of a Ukrainian grain ship from the Black Sea for the first time since February. He also used the statement to call on Russia to “end its attacks that are rendering farmland in Ukraine unusable and destroying agricultural infrastructure. As long as Russia continues its aggression, the Ukrainian people and the world’s most vulnerable will continue to suffer its effects.” (https://www.state.gov/first-grain-ship-departs-the-black-sea/).
  • US-Led Price Cap Faces Resistance from Insurers Abroad: On Wednesday, The New York Times reported that UK and EU-based insurance groups were pushing back on a US-led proposal that would impose a price cap on Russian oil. Insurers, who would need to verify the price at which oil was purchased, are skeptical about the enforceability of the proposal, particularly if only a handful of countries go along with the cap. Nevertheless, the price cap remains an important talking point for Biden administration officials in meetings with their counterparts. (https://www.nytimes.com/2022/08/03/us/politics/us-russia-oil-prices.html).
  • Treasury Department Issues Technical Amendments to August 2 General Licenses: On Wednesday, the Treasury Department issued technical amendments to General Licenses 40A, 47, and 48 to update the name of Joint Stock Company State Transportation Leasing Company. Treasury noted that Tuesday’s issuance of these General Licenses omitted the word “Leasing” from the name. (https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220803).
  • US Senate Moves to Ratify NATO Membership for Sweden and Finland: On Wednesday, the US Senate approved, in a 95-1 vote, approval of a treaty to include Finland and Sweden in NATO. Their admission will require approval by all 30 current NATO members, with 22 members already having done so. (https://www.nytimes.com/2022/08/03/world/europe/sweden-finland-nato-senate-vote.html).

UPDATE:

August 02, 2022

  • State, Treasury Departments Issue New Sanctions on Elites and Companies Generating Substantial Revenue for the Russian Regime: On Tuesday, the US State Department and the US Department of Treasury’s Office of Foreign Assets Control (“OFAC”) announced new sanctions on a range of Russian elites, companies, educational and scientific institutions, a vessel, and Turkish entities in connection with operating in economic sectors that generate substantial revenue for the Russian regime, including from sources outside of Russia. The US government also took the following actions:
  • Designation of Joint Stock Company Promising Industrial and Infrastructure Technologies (“JSC PPIT”), a financial institution owned by the Russian Federal Agency for State Property Management, which attempted to facilitate the circumvention of sanctions imposed on the Russian Direct Investment Fund (“RDIF”) through a transfer of cash and assets in anticipation of RDIF’s designation by OFAC as an SDN.
  • Issuing General License 40A with regards to the provision, exportation, or reexportation of goods, technology, or services to ensure the safety of civil aviation to certain blocked entities identified in the Annex to General License 40A. General License 40A replaces previously issued General License 40.
  • Issuing General License 43A authorizing the divestment or Transfer of debt or equity of, and wind down of derivative contracts involving Public Joint Stock Company Severstal or Nord Gold PLC through 12:01 a.m. ET on August 31, 2022. General License 43A replaces previously issued General License 43.
  • Issuing General License 47 authorizing transactions ordinarily incident and necessary to the wind down of any transaction involving certain entities specified in the General License blocked by OFAC on August 2, 2022 through 12:01 a.m. ET, September 1, 2022.
  • Issuing General License 48 authorizing transactions ordinarily incident and necessary to the divestment or transfer, or facilitation of the divestment or transfer, of debt or equity of Publichnoe Aktsionernoe Obschestvo Magnitogorskiy Metallurgicheskiy Kombinat,  Joint Stock Company Government Transport Company, or their 50% or more owned subsidiaries, purchased prior to August 2, 2022, to a non-U.S. person through 12:01 a.m. ET on October 3, 2022.
  • Issuing General License 49 authorizing transactions ordinarily incident and necessary to the wind down of any transaction involving MMK Metalurji Sanayi Ticaret Ve Liman Isletmeciligi Anonim Sirketi (MMK Metalurji) or any entity 50% or more owned by MMK Metalurji.
  • Issuing three new Frequently Asked Questions clarifying that: (1) “OFAC has not designated PhosAgro PJSC and, based on information available to OFAC, PhosAgro PJSC is not owned 50% or more by blocked persons or otherwise considered the blocked property of Andrey Grigoryevich Guryev and Andrey Andreevich Guryev”; (2) “EuroChem Group AG and, based on information available to OFAC, EuroChem Group AG is not owned 50% or more by blocked persons or otherwise considered the blocked property of Andrey Igorevich Melnichenko”; and (2) “OFAC has not designated Sheremetyevo International Airport and, based on information available to OFAC, Sheremetyevo International Airport is not owned 50% or more by blocked persons or otherwise considered the blocked property of Alexander Anatolevich Ponomarenko.”(https://www.state.gov/imposing-additional-costs-on-russia-for-its-continued-war-against-ukraine/;https://home.treasury.gov/news/press-releases/jy0905; https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220802).
  • BIS Identifies Foreign-Made Aircraft Flown to Russia and Belarus: On Tuesday, the Department of Commerce Bureau of Industry and Security (“BIS”) identified an additional 25 aircraft flown to Russia and Belarus in violation of US export control laws. All 25 planes were foreign made, though the amount of US content on these aircraft was above the de minimis thresholds needed to exclude the planes from US export controls. (https://www.bis.doc.gov/index.php/documents/about-bis/newsroom/press-releases/3108-2022-08-02-bis-press-release-gp10-list-foreign-produced-de-minimis-additions/file).
  • Secretary of State Accuses Russia of “Nuclear Saber Rattling”: During Monday’s Nuclear Nonproliferation Treaty Review at the United Nations, Secretary of State Antony Blinken accused Russia of “reckless, dangerous nuclear saber rattling” by threatening countries that support Ukraine with “consequences such as you have never seen in your entire history.” (https://www.cnn.com/2022/08/01/politics/blinken-npt-remarks/index.html).
  • Treasury Secretary Yellen Speaks with German Counterpart: On Tuesday, US Treasury Secretary Janet L. Yellen spoke with German Finance Minister Christian Lindner, where she “discussed the critical need to respond to Ukraine’s near-term economic assistance needs caused by Russia’s unprovoked and unjustified war” and “conveyed appreciation for Germany’s key role, as part of its G7 presidency, in exploring a price cap on Russian oil and in the progress being made in technical-level discussions.” (https://home.treasury.gov/news/press-releases/jy0907).
  • English Foreign Language Testing Agency Blocks Russian Test Takers: On Tuesday, Mediazona reported that several Russian nationals who were registered to sit for the Test of English as a Foreign Language (“TOEFL”) had received notifications that they were blocked for sitting for the upcoming TOEFL exam due to sanctions on Russia. The test is a widely used credential at higher education institutions. (https://www.themoscowtimes.com/2022/08/02/russians-banned-from-toefl-english-language-exam-report-a78486).

UPDATE:

August 01, 2022

UPDATE:

July 29, 2022

  • OFAC Announces New Sanctions on Russian Individuals and Entities Involved in Election Interference: On Friday, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced new designations of individuals and entities that it stated “played various roles in Russia’s attempts to manipulate and destabilize the United States and its allies and partners, including Ukraine,” clarifying these measures were imposed “separate and distinct from the broad range of high impact measures the United States and its allies and partners continue to impose on Russia for its war against Ukraine, which is another clear example of the Kremlin’s disregard for the sovereignty – and independence – of other states.” The designations included that of Russian national Aleksandr Viktorovich Ionov and associated organizations, with OFAC stating he “has been an FSB co-optee who uses his positions and various companies to promulgate the Kremlin’s disinformation and malign influence agenda.” In conjunction, the US Department of Justice also unsealed an indictment charging Ionov for his foreign malign influence activities against the United States. (https://home.treasury.gov/news/press-releases/jy0899; https://www.justice.gov/opa/pr/russian-national-charged-conspiring-have-us-citizens-act-illegal-agents-russian-government).
  • Blinken, Lavrov Speak: On Friday, Secretary of State Antony Blinken and Russian Foreign Minister Sergei Lavrov held a phone call, the first contact between the Ministers since the invasion of Ukraine began. Secretary Blinken urged Lavrov to accept the “substantial proposal” put forth by the US that will exchange one detained Russian arms dealer for two American hostages in Russia. Blinken also pressed Lavrov to uphold Russia’s commitment to secure grain exports through the Black Sea. (https://www.reuters.com/world/russias-lavrov-says-moscow-will-propose-time-call-with-blinken-2022-07-29/).
  • State Department Hesitant to Label Russia as State Sponsor of Terrorism: As pressure builds on the State Department to formally label Russia as a state sponsor of terrorism, Secretary of State Antony Blinken has thus far remained non-committal on the issue, saying, “costs that have been imposed on Russia by us and by other countries are absolutely in line with the consequences that would follow from designation as a state sponsor of terrorism. So the practical effects of what we’re doing are the same.” Administration officials also told The New York Times that they feared the designation would restrict the administration’s ability to exempt certain critical transactions with Russia in the future. (https://www.nytimes.com/2022/07/29/us/politics/russia-terrorism-blinken.html).
  • US Hosts First US-Japan Economic Policy Consultative Committee, Reiterate Commitment to Countering Russia: On Friday, Secretary of State Antony Blinken and Secretary of Commerce Gina Raimondo hosted Japanese Foreign Minister Hayashi Yoshimasa and Minister of Economy, Trade and Industry Haiguda Koichi for the first US-Japan Economic Policy Consultative Committee. The group discussed various economic issues, but their joint release condemned Russian aggression in Ukraine and expressed a willingness to work together on food security and energy security issues emanating from the conflict, including a commitment to decarbonization in the long term and expanding oil and gas drilling in the near term. (https://www.commerce.gov/news/press-releases/2022/07/joint-statement-us-japan-economic-policy-consultative-committee).

UPDATE:

July 28, 2022

  • Senate Passes Resolution to Label Russia as a Sponsor of Terrorism: On Wednesday, the U.S. Senate unanimously approved a resolution calling on the State Department to designate Russia as a state sponsor of terrorism for its killing of innocent civilians in Chechnya, Georgia, Syria, and Ukraine. The nonbinding resolution must be approved by the State Department to take effect. (https://www.nytimes.com/2022/07/27/world/europe/the-us-senate-passes-a-resolution-seeking-to-label-russia-as-a-sponsor-of-terrorism.html).
  • Blinken Plans to Meet Sergei Lavrov in Coming Days: Secretary of State Blinken plans to speak with Russian Foreign Minister Sergei Lavrov soon to discuss several issues, including the detentions of Brittney Griner and other Americans. Blinken also plans to discuss relaxing the Black Sea blockade, Lavrov’s recent remarks that Russia’s territorial claims extend beyond Ukraine’s Donbas region, and the U.S.’s commitment to Ukraine’s sovereignty. This would be the first meeting between the two diplomats since Russia invaded Ukraine on February 24. (https://www.axios.com/2022/07/27/blinken-lavrov-ukraine-russia-invasion-griner).
  • U.S. Offers Russia Prisoner Swap for Two Americans: On Wednesday, Secretary of State Antony Blinken announced that the U.S. has proposed a prisoner swap for two Americans being held by Russia, Brittney Griner and Paul Whelan. President Biden has backed the offer that would release the imprisoned arms dealer Viktor Bout to Russia. (https://www.nytimes.com/live/2022/07/27/world/russia-war-ukraine).

UPDATE:

July 27, 2022

  • US Accounting Firms Push Clients to Disclose Russia Ties: The Wall Street Journal reported on Wednesday that major auditing firms are demanding that their clients promise that they have no significant Russia connections in order to reduce sanctions risk. For example, BDO USA is going beyond what the US currently requires by sending engagement letters to clients, requiring them to attest that no Russian entities own more than 5% of their stock. The Big Four are also stepping up their checks, and last month EY was the last of the four to formally separate from Russia. US, UK, and European sanctions ban firms from providing accounting services to most Russian companies and individuals. (https://www.wsj.com/articles/auditors-press-clients-on-russia-connections-11658879879?mod=hp_lead_pos6).
  • Senators Introduce Legislation Imposing Sanctions on Insuring, Registering Russian Oil Tankers: On Tuesday, Republican Senators Marco Rubio (R-FL), Rick Scott (R-FL), and Kevin Cramer (R-ND) introduced a bill to impose penalties on any entity insuring or registering tankers that ship oil or natural gas to China from Russia. The bill conflicts with the Biden administration’s policy to keep oil supplies flowing and is likely to face stiff opposition in the Democratic-controlled Congress. (https://www.bloomberg.com/news/articles/2022-07-26/u-s-senators-call-for-sanctions-on-russian-oil-sales-to-china#xj4y7vzkg;https://www.rubio.senate.gov/public/index.cfm/press-releases?ID=D22EED57-55D3-446D-B767-28CA59F99532).
  • Treasury to Contribute $500 Million to EBRD: On Tuesday, the Treasury Department announced that the US would contribute $500 million to the European Bank for Reconstruction and Development (“EBRD”). The funding will support immediate crisis response, primarily in Ukraine, including funding for energy security, food security, and support for vulnerable populations and displaced persons. (https://home.treasury.gov/news/press-releases/jy0892).
  • Treasury Official Praises Sanctions and Economic Support Efforts for Ukraine in Senate Hearing: During a Wednesday hearing before the Senate Foreign Relations Committee, Acting Under Secretary of the Treasury for international Affairs Andy Baukol said that, as a result of cooperation among allies, the US has “levelled some of the strongest and most effective sanctions in history—and the Russian economy has been left reeling.” He also discussed US economic assistance sent to Ukraine, highlighting the $4 Billion in budget support sent to the Ukrainian government. (https://home.treasury.gov/news/press-releases/jy0891).
  • Deputy Secretary of the Treasury Pushes for Oil Price Cap in Belgium: In Tuesday meetings with the European Commissioner for Economy Paolo Gentiloni and Head of Cabinet of the President of the European Commission Bjoern Seibert, Deputy Secretary of the Treasury Wally Adeyemo discussed “continued support for the people and government of Ukraine.” The group also discussed a price cap on Russian oil, as the Treasury Department continues its campaign to build support for the policy. (https://home.treasury.gov/news/press-releases/jy0890).
  • NASA Contests Russia’s Announced Plans to Withdraw from ISS: On Tuesday, Russia’s space agency announced that the country would withdraw from the International Space Station (“ISS”) by 2024. However, NASA counterparts report that Russia has not conveyed to them an intent to end its ISS partnership as required by the countries’ joint agreement. (https://www.reuters.com/technology/russia-has-not-signaled-space-station-withdrawal-nasa-us-official-says-2022-07-26/).

UPDATE:

July 26, 2022

  • SEC Seeks More Details From Companies on Russia-Linked Losses, Risks: The U.S. securities regulator in May published a list detailing the information it seeks from companies to ensure that investors can adequately assess risks. The Wall Street Journal reported that, in recent weeks, it has sent out additional queries and, in some cases, follow up questionnaires to impacted companies. Companies will likely make additional disclosures as they wind down their operations in Russia, potentially taking hefty impairment charges as a result. (https://www.wsj.com/articles/sec-seeks-more-details-from-companies-on-russia-linked-losses-risks-11658827982?mod=hp_minor_pos7).
  • Deputy Secretary of the Treasury Adeyemo Meets with French Counterpart: On Tuesday, Deputy Treasury Secretary Wally Adeyemo met with Secretary-General of the Élysée Palace Alexis Kohler and Director General of the Treasury Emmanuel Moulin. The group discussed their commitment to the people of Ukraine, the need to continue to speed budgetary support and suspend debt service for Ukraine, and opportunities to build on the historic sanctions imposed on Russia. Adeyemo also met with financial services executives to discuss ways to alleviate global energy prices and food insecurity. They reviewed ways to alleviate those impacts, particularly a price cap on Russian oil to stabilize global energy markets and supporting Ukraine’s efforts to export grain. (https://home.treasury.gov/news/press-releases/jy0886).
  • McDonald’s Revenue Down 3% on Russia Exit: On Tuesday, McDonald’s posted a 3% drop in revenue to $5.72 billion, coming in under analyst projections of $5.8 billion, according to FactSet. The company said its profit fell by nearly half to $1.19 billion, or $1.60 a share, during the second quarter, due in part to a pretax charge coming from the sale of its business in Russia. McDonald’s officially exited Russia in May after more than three decades of operations there, selling its hundreds of restaurants to a local franchisee. (https://www.wsj.com/articles/mcdonalds-revenue-down-3-on-russia-exit-weaker-euro-11658837112).
  • White House Announces New Sale from Strategic Petroleum Reserve: On Tuesday, the Biden Administration announced that it is releasing the next Notice of Sale to supply additional barrels of crude oil from the Strategic Petroleum Reserve (“SPR”) onto the global market, building on the more than 125 million barrels of oil that have already been sold out of the reserve as sanctions impact energy prices worldwide. The Department of Treasury estimates that these releases, along with coordinated releases from international partners, have reduced gasoline prices by up to about 40 cents per gallon compared to what they would have been absent these drawdowns. The administration intends to repurchase oil for the SPR after 2023, and plans to allow fixed-price forward purchases of crude oil to replenish SPR and encourage short term production. (https://www.whitehouse.gov/briefing-room/statements-releases/2022/07/26/fact-sheet-department-of-energy-releases-new-notice-of-sale-as-gasoline-prices-continue-to-fall/; https://www.whitehouse.gov/briefing-room/statements-releases/2022/07/26/fact-sheet-department-of-energy-releases-new-notice-of-sale-as-gasoline-prices-continue-to-fall/).

UPDATE:

July 25, 2022

  • US Ambassador to Ukraine Says Administration is “Seriously Considering” Declaring Russia State Sponsor of Terrorism: In a Sunday interview, US Ambassador to Ukraine Bridget Brink said that the US is “seriously considering” designating Russia as a state sponsor of terrorism. She added that any designation would require “careful analysis in accordance with American laws.” (https://www.yahoo.com/news/us-seriously-considering-declaring-russia-140700042.html).
  • Bipartisan House Delegation Meets with Ukrainian President in Kyiv: On Saturday, Adam Smith (D-WA), Michael Waltz (R-FL), Elissa Slotkin (D-MI), Mikie Sherrill (D-NJ), and Mike Quigley (D-IL) met with Ukrainian President Volodymyr Zelenskyy in Kyiv. The group discussed the recently-announced $270 million security assistance package, and post-conflict reconstruction efforts in Ukraine. (https://thehill.com/policy/international/3571623-bipartisan-house-delegation-meets-with-zelensky-in-kyiv/).
  • Secretary of State Condemns Weekend Missile Attack on Odessa: On Saturday, Secretary of State Antony Blinken released a statement condemning the missile attack on Odessa earlier that day. He stated that the “attack casts serious doubt on the credibility of Russia’s commitment to yesterday’s deal and undermines the work of the UN, Turkey, and Ukraine to get critical food to world markets.” (https://www.state.gov/the-united-states-strongly-condemns-the-russian-missile-attack-against-odesa/).

UPDATE:

July 22, 2022

UPDATE:

July 21, 2022

UPDATE:

July 20, 2022

  • Department of Justice Asks Congress for RICO Reform to Enforce Sanctions: During a Congressional hearing on Tuesday, Department of Justice official Andrew Adams asked Congress for permission to use the Racketeer Influenced and Corrupt Organizations Act (“RICO”) as a means to pursue sanctioned Russian assets in the United States. The rule change would allow authorities to take control of, rather than only freeze, sanctioned Russian assets in the US. (https://thehill.com/policy/finance/3566376-doj-pitches-senate-on-use-on-anti-mafia-laws-to-seize-russian-assets/)

  • Group Creditors of Ukraine to Honor Ukraine’s Request for Suspension of Debt Service: The Group of Creditors of Ukraine, which includes the US, 5 other participants, and observers in 15 counties, announced on Wednesday their intent to honor Ukraine’s request for a coordinated suspension of debt service through the end of 2023. Treasury Secretary Janet Yellen welcomed the development, and added, “I reiterate the call to all other bilateral official and private creditors to join this initiative and assist Ukraine as it defends itself from Russia’s unprovoked and brutal war.” (https://home.treasury.gov/news/press-releases/jy0884; https://home.treasury.gov/news/press-releases/jy0883)

UPDATE:

July 19, 2022

  • US Prosecutors Ask Congress For Broader Powers To Seize Assets Of Russian Oligarchs: During a hearing before the Senate Judiciary Committee on Tuesday, head of the U.S. Department of Justice’s KleptoCapture task force Andrew Adams asked Congress to provide the DOJ with broader authority to “seize Russian oligarchs’ assets” by increasing the statute of limitation for certain financial crimes to ten years and by allowing the “forfeiture of assets used to evade U.S. sanctions” in an attempt to “increase pressure on Moscow over its invasion of Ukraine.” (https://www.rferl.org/a/russian-oligarchs-asset-seizures-congress/31950695.html).

  • Secretary of the Treasury Meets with Korean Leaders: In a Tuesday meeting with Korean President Yoon Suk Yeol, Secretary of the Treasury Janet Yellen “discussed ongoing efforts to hold Russia accountable for its brutal and illegal war against Ukraine—including through a price cap on Russian oil to reduce the impact of Putin’s war on global energy prices while limiting revenue for Russia’s war machine.” She expressed similar sentiments in a meeting with Korean Deputy Prime Minister Choo Kyung-ho. (https://home.treasury.gov/news/press-releases/jy0878; https://home.treasury.gov/news/press-releases/jy0877).

UPDATE:

July 18, 2022

  • Ukrainian Officials Accuse Major Tech Companies of Failing to Remove Russian Propaganda: As the conflict in Ukraine drags on, Ukrainian officials are alleging that major US tech companies are not upholding their commitment to remove Russian propaganda from their platforms. The Washington Post reported that Ukrainian officials have flagged thousands of posts on Twitter and YouTube that are in violation of misinformation policies implemented after the invasion of Ukraine, but are still on the platforms. (https://www.washingtonpost.com/technology/2022/07/14/ukraine-takedown-requests-russia-propaganda/).

  • Deputy Treasury Secretary Discusses Russia Response with Moldovan PM: In a Monday meeting with Moldovan Prime Minister Natalia Gavrilița, Deputy Treasury Secretary Wally Adeyemo discussed “global economic spillovers caused by Russia’s unprovoked and unjustified war against Ukraine.” They also discussed external financing multilateral organizations have provided to Moldova in response to the invasion, including $130 million from the US. (https://home.treasury.gov/news/press-releases/jy0876).

UPDATE:

July 15, 2022

  • House Passes Amendment on CAATSA Sanctions Waiver for India: On Thursday, the House of Representatives passed a legislative amendment to approve a waiver to India under the Countering America’s Adversaries Through Sanctions Act (CAATSA) for its purchase of the 2-400 missile defense system from Russia. Congressman Ro Khanna introduced the amendment, which urges the Biden administration to use its authority to provide India with a waiver. Khanna said, “The United States must stand with India in the face of escalating aggression from China. As Vice Chair of the India Caucus, I have been working to strengthen the partnership between our countries and ensure that India can defend itself along the Indian Chinese border.” (https://www.ndtv.com/india-news/us-house-of-representatives-votes-for-india-specific-caatsa-sanctions-waiver-3159584).

  • Yellen Meets with Indonesian Finance Minister at G20 Summit: At the G20 Finance Ministers and Central Bank Governors Meeting, Treasury Secretary Janet Yellen met with Indonesian Finance Minister Sri Mulyani Indrawati to express the importance of a price cap on Russian oil and reiterate a commitment in working closely with Indonesia through the food security crisis exacerbated by the Russian invasion of Ukraine. (https://home.treasury.gov/news/press-releases/jy0871).

UPDATE:

July 14, 2022

  • OFAC Releases Fact Sheet on Agricultural Sanctions: On Thursday, OFAC released a fact sheet clarifying that US sanctions on Russia do not restrict “the production, manufacturing, sale, or transport of agricultural commodities (including fertilizer), agricultural equipment, or medicine.” It clarifies that sanctions do not restrict insurance on shipments of agricultural products from or involving Russia, as well. It also notes that, while Russian-origin seafood may not be imported to the United States, US persons are not exposed to sanctions for arranging for Russian-origin seafood imports in other jurisdictions, so long as the transaction does not ultimately bring the Russian seafood to the US or involve an otherwise sanctioned person or transaction. (https://home.treasury.gov/system/files/126/russia_fact_sheet_20220714.pdf).

  • OFAC Removes Kazakh Affiliates of Alfa Bank from SDN List: On Thursday, OFAC announced that it had removed SUBSIDIARY BANK ALFA-BANK JSC (a.k.a. JSC SB ALFA BANK) and JSC SB ALFA BANK (a.k.a. SUBSIDIARY BANK ALFA-BANK JSC) from the specially designated nationals list. Both entries referred to Alfa Bank’s Kazakh subsidiary in Almaty. (https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220714).

  • Yellen Holds Press Conference Ahead of G20 Summit in Indonesia, Pushes for Price Cap: Treasury Secretary Janet Yellen pushed for a price cap on Russian oil at a news conference on Thursday ahead of the G20 summit of finance ministers in Bali. Yellen mentioned an exception that would allow Russia to export as long as the price does not exceed a certain level. Yellen also discussed the “deteriorating global economic conditions” since the Russian invasion of Ukraine and debt restructuring for developing countries. (https://home.treasury.gov/news/press-releases/jy0865).

  • Biden Reiterates Commitment to Support Ukraine in Visit to Israel: During President Biden’s four-day visit to Israel and Saudi Arabia, he spoke at a news conference in Jerusalem, reaffirming U.S. commitment to help Ukraine defend its democracy. He stated that, “Putin’s war must be a strategic failure.” While Israel has expressed support for Ukraine, Israel’s government has been wary of being too critical of Russia in order to avoid provoking problems in the Middle East. (https://www.nytimes.com/2022/07/14/world/middleeast/biden-israel-food-crisis-ukraine.html?smid=url-share).

UPDATE:

July 13, 2022

  • White House Releases Press Statement on Russia’s “Filtration” Operations and Forced Deportation: Secretary of State Antony Blinken released a press statement on Wednesday calling on Russia to halt its “filtration” operations and forced deportations of Ukrainian citizens. The statement condemned Russia’s forced deportations as a “grave breach” of the Fourth Geneva Convention. Blinken called for the immediate release of detained Ukrainian citizens and to provide independent third parties access to the “filtration” facilities. (https://www.state.gov/russias-filtration-operations-forced-disappearances-and-mass-deportations-of-ukrainian-citizens/).

  • Comment on EU Sanctions and Shipments from Kaliningrad: The State Department issued a press statement Wednesday that welcomed the EU announcement about its implementation of economic sanctions on Russia with respect to Kaliningrad. The statement applauded the actions of the EU member states but noted that “there is not now and there never has been a so-called ‘blockade’ of Kaliningrad.” (https://www.state.gov/eu-sanctions-on-russia-and-shipments-to-and-from-kaliningrad/).

  • State Department Official Discusses Future Sanctions: Deputy Assistant Secretary of State for the Bureau of Economic and Business Affairs, Erik Woodhouse, stated that the administration will continue to identify “additional targets” to escalate economic pressure on Russia if necessary in a Wednesday news conference at the State Department’s Foreign Press Center. Woodhouse declined to comment on the specifics of any potential future sanction actions. He also stated that the U.S. has “borne some of the costs” of sanctions on Russia, but noted that European countries “face a more intense situation.” (https://tass.com/politics/1479587; https://tass.com/world/1479605).

  •  Treasury Secretary Discusses U.S. Economic Assistance for Ukraine with Finance Minister: Deputy Secretary of the Treasury Wally Adeyemo discussed further U.S. aid to Ukraine with Ukraine Minister of Finance Sergii Marchenko in a call on Wednesday. Adeyemo reaffirmed the U.S. commitment to Ukraine and the Treasury’s continued role in sanctions on Russia. Adeyemo and Marchenko also discussed progress towards implementing a price cap on Russian oil. (https://home.treasury.gov/news/press-releases/jy0864).

UPDATE:

July 12, 2022

UPDATE:

July 11, 2022

  • Secretary of State Blinken Presses China to Avoid Neutrality in Russia-Ukraine Conflict: During G20 meetings on Saturday, Secretary of State Antony Blinken met with Chinese Foreign Minister Wang Yi for five hours, and urged him to join the international community and “stand up” against Russia’s war in Ukraine. Chinese press surrounding the meeting said that Foreign Minister Wang accused Secretary Blinken of “recycling Cold War-era strategies of containment” and the US more generally of having “China-phobia.” (https://www.nytimes.com/2022/07/09/world/europe/ukraine-blinken-russia-war.html?smid=url-share).

  • US Pressing Allies to Provide Soviet-Made Weapons to Ukraine: Anticipating that the US will not authorize additional military assistance to Ukraine once the current funding allocation runs out, the Biden administration is reportedly pressuring allies to provide Ukraine with Soviet-made weapons, which Ukrainian forces are already familiar with. President Biden is expected to raise this issue during his upcoming travel to the Middle East. (https://www.nytimes.com/2022/07/09/us/politics/ukraine-strategy-biden.html?searchResultPosition=2).

  • National Security Advisor Says Iran is Prepared to Supply Russia with Weapons-Capable Drones: Speaking to assembled press on Monday, National Security Advisor Jake Sullivan said that the US has intelligence indicating that Iran is prepared to supply Russia with drones, including weapons-capable drones, as early as July. He said, “[i]t’s unclear whether Iran has delivered any of these UAVs to Russia already. But this is just one example of how Russia is looking to countries like Iran for capabilities that … have been used before we got the ceasefire in place in Yemen to attack Saudi Arabia.” (https://www.cnn.com/world/live-news/russia-ukraine-war-news-07-11-22/h_f4da6dd2c321fea1ae0bdcdb43a915e5).

  • USAID Approves $1.7 Billion in Assistance for Ukraine: On Saturday, Ukrainian Prime Minister Denys Shymal announced that the Ukrainian government and the US Agency for International Development (“USAID”) had reached an agreement for a $1.7 billion grant to Ukraine for medical guarantees. (https://news.yahoo.com/ukraine-receive-1-7-billion-141600019.html).

UPDATE:

July 08, 2022

  • Sanctions on Russian Debt Complicating Insurance Payouts: After Russia defaulted on its debt in May, investors, like US bond giant PIMCO, are waiting for guidance from the Treasury Department’s Office of Foreign Assets Control (“OFAC”) on the legality of credit default swap auctions of Russian debt. OFAC currently restricts US investors from purchasing Russian securities in secondary markets. Analysts have described the situation as “unprecedented,” and if the situation remains unresolved, sellers may look to private sales of Russian credit default swaps. (https://www.reuters.com/markets/europe/sanctions-russias-debt-entangle-default-insurance-payouts-2022-07-08/).

  • State Department Official Highlights Sanctions Impact: Speaking at a Washington Foreign Press Center briefing on Thursday, Deputy Assistant Secretary of State for European and Eurasian Affairs Douglas Jones highlighted the impact of sanctions on the Russian economy, and promised to maintain sanctions pressure. He said, “we will continue to put the economic pressure on Russia and raise the cost to Russia for this going forward, not only to continue the sanctions but continue to broaden them, and also to enhance their implementation to make sure that enforcement is stronger. And we’ll continue that as long – as the leaders said, continue this as long as it takes.” (https://www.state.gov/briefings-foreign-press-centers/key-outcomes-from-the-madrid-summit).

UPDATE:

July 07, 2022

  • Senators Graham, Blumenthal Visit Kyiv: On Thursday, Senators Richard Blumenthal (D-CT) and Lindsey Graham (R-SC) met with Ukrainian President Volodymyr Zelenskyy in Kyiv. President Zelenskyy praised the bipartisan nature of this delegation, saying it demonstrates the deep support for Ukraine in the US legislature. Though discussion appeared to focus on US security assistance to Ukraine, the group also discussed increasing sanctions; according to the Ukrainian President’s press office, “Lindsey Graham and Richard Blumenthal informed Volodymyr Zelenskyy about the work they are carrying out in the Senate with the aim of recognizing the Russian Federation as a state sponsor of terrorism.” (https://www.president.gov.ua/en/news/prezident-zustrivsya-iz-senatorami-ssha-lindsi-gremom-i-rich-76337).

UPDATE:

July 06, 2022

  • Secretary of State Calls Ukrainian Counterpart: On Wednesday, Secretary of State Antony Blinken called Ukrainian Foreign Minister Dmytro Kuleba. They discussed the upcoming G20 foreign minister’s meeting, multilateral efforts to improve agricultural exports out of Ukraine, and US security assistance to Ukraine, including a preview of coming budget support for Ukraine. (https://www.state.gov/secretary-blinkens-call-with-ukrainian-foreign-minister-kuleba-26/).

  • FBI Director Suggests China Taking Lessons from Russia Sanctions: In a rare public statement during a trip to the UK on Wednesday, FBI Director Christopher A. Wray warned the threat posed by the Chinese government to Western companies is “getting worse” and suggested China may be taking steps to insulate itself from economic repercussions if it invades Taiwan. He noted that China “is drawing all sorts of lessons from what’s happening with Russia and its unprovoked invasion of Ukraine.” (https://www.washingtonpost.com/national-security/2022/07/06/china-taiwan-fbi-wray-sanctions/).

UPDATE:

July 05, 2022

  • Google Sold Data of Ukrainian Users to Russia Even After Sanctions: Despite warnings from US Senate Intelligence Committee, Google shared potentially sensitive user data with the sanctioned Russian advertising company RuTarget, even after the US imposed harsh sanctions after the invasion of Ukraine, according to analytics company Adalytics. Among the data were unique identifiers of mobile phones, IP addresses, information about the location of users, their interest, and internet activity, which may be used by Russians to track Ukrainian users. (https://news.yahoo.com/google-sold-data-ukrainian-users-150500294.html).

  • State Department Releases Statement Calling for Reduced Russian, Belarusian Participation on International Sporting Bodies: On Tuesday, the State Department released a statement with 34 other partners calling on (i) international sport federations to suspend Russian and Belarusian government participation; (ii) international sport federations to remove Russian and Belarusian officials with close ties to their respective governments; and (iii) national and international sports organizations to consider suspending competition broadcasts into Russia and Belarus. They state that, if Russian and Belarusian members continue to participate in such organizations, the organization should confirm that these individuals are acting independently. (https://www.state.gov/second-statement-on-russias-war-on-ukraine-international-sport/).

UPDATE:

July 04, 2022

  • New York Times Profiles U.S. Military Unit Organizing Weapons Shipments to Ukraine: On Sunday, The New York Times released a profile of United States Transportation Command (“Transcom”), a centralized group of military logisticians that organizes shipments of US weapons to Ukraine based out of an Illinois airfield. The article discusses their planning efforts, which often begin well before the official announcement of any weapons transfer, and their execution. (https://www.nytimes.com/2022/07/03/us/ukraine-military-aid-weapons-us.html).  

UPDATE:

July 01, 2022

  • U.S. Official States Chinese Government Not Supporting Russian War: Speaking to Reuters, an unnamed senior administration official said on Thursday, that the Chinese government is not supporting Russia in the conflict in Ukraine. The official added that enforcement measures taken earlier in the week targeted certain Chinese companies, not the government. The official said, “China is not providing material support. This is normal course-of-business enforcement action against entities that have been backfilling for Russia.”(https://www.reuters.com/world/china-not-giving-material-support-russias-war-ukraine-us-official-2022-07-01/).

  • Treasury Secretary Discusses Russian Oil Cap in Call with Korean Counterpart: On Friday, Treasury Secretary Janet Yellen called Minister of Economy and Finance of the Republic of Korea Choo Kyung-ho. A readout of their meeting from Treasury indicates that they discussed “the merits of a price cap on Russian oil to restrict revenue to the Kremlin that finances their unjust and illegal actions.” (https://home.treasury.gov/news/press-releases/jy0847).

  • Treasury Official Discusses Oil Price Cap in Japan: Much like Secretary Yellen, Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian Nelson discussed the “design and implementation of the [oil] price cap” during a trip to Japan on Friday to meet with Finance Vice Minister Masato Kanda, Deputy Minister of Foreign Affairs Masataka Okano, Ministry of Economy, Trade, and Industry Director-General Yoichi Iida, Cabinet Councillor Toshio Oya, and Financial Services Agency Deputy Director-General Toshiyuki Miyoshi. (https://home.treasury.gov/news/press-releases/jy0846).

UPDATE:

July 01, 2022

  • U.S. Official States Chinese Government Not Supporting Russian War: Speaking to Reuters, an unnamed senior administration official said on Thursday, that the Chinese government is not supporting Russia in the conflict in Ukraine. The official added that enforcement measures taken earlier in the week targeted certain Chinese companies, not the government. The official said, “China is not providing material support. This is normal course-of-business enforcement action against entities that have been backfilling for Russia.”(https://www.reuters.com/world/china-not-giving-material-support-russias-war-ukraine-us-official-2022-07-01/).

  • Treasury Secretary Discusses Russian Oil Cap in Call with Korean Counterpart: On Friday, Treasury Secretary Janet Yellen called Minister of Economy and Finance of the Republic of Korea Choo Kyung-ho. A readout of their meeting from Treasury indicates that they discussed “the merits of a price cap on Russian oil to restrict revenue to the Kremlin that finances their unjust and illegal actions.” (https://home.treasury.gov/news/press-releases/jy0847).

  • Treasury Official Discusses Oil Price Cap in Japan: Much like Secretary Yellen, Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian Nelson discussed the “design and implementation of the [oil] price cap” during a trip to Japan on Friday to meet with Finance Vice Minister Masato Kanda, Deputy Minister of Foreign Affairs Masataka Okano, Ministry of Economy, Trade, and Industry Director-General Yoichi Iida, Cabinet Councillor Toshio Oya, and Financial Services Agency Deputy Director-General Toshiyuki Miyoshi. (https://home.treasury.gov/news/press-releases/jy0846).

UPDATE:

June 29, 2022

  • U.S. Secretary of Commerce Praises Efficacy of Export Controls on Russia: At the Bureau of Industry and Security (“BIS”) Update Conference, U.S. Secretary of Commerce Gina Raimondo spoke about the effects of the controls put in place on Russia with regards to global exports and aerospace controls. Raimondo stated that, since the controls were put in place, global exports of semiconductors to Russia from all sources have declined by almost 90 percent. Additionally, the aerospace controls put in place have led Russia to potentially ground between half and two-thirds of its commercial aircraft by 2025 in order to cannibalize them for spare parts. (https://www.commerce.gov/news/speeches/2022/06/remarks-us-secretary-commerce-gina-raimondo-bureau-industry-and-security-bis).

  • U.S. and Allies REPO Task Announces Action on More Than $30 Billion in Frozen Assets: The Russian Elites, Proxies, and Oligarchs (“REPO”) Task Force, an international coalition between the U.S. and allied devoted to sanctions enforcement, stated Wednesday that it has blocked or frozen more than $30 billion worth of sanctioned Russians’ assets, immobilized $300 billion in Russian Central Bank Assets, frozen or seized various items of luxury property, and heavily restrict sanctioned Russians’ access to the international financial system. The Task Force committed to continued enforcement efforts along these lines. (https://home.treasury.gov/news/press-releases/jy0839)

  • Gas Prices Test American Appetite for New Cold War with Russia: Self-sanctioning and Putin’s deliberate reduction in gas flows have sent energy costs up sharply in the West, undermining their leaders’ political standing. President Biden has begun pivoting his agenda, pushing to export more liquefied natural gas to Europe and patching up relations with Saudi Arabia. The U.S. is a net exporter of petroleum and related products, and is the most important player in the West’s effort to wean itself off Russian energy. (https://www.wsj.com/articles/americans-balk-at-the-price-of-a-new-cold-war-with-russia-11656505721?mod=hp_lead_pos13)

UPDATE:

June 28, 2022

  • Treasury Department Sanctions Nearly 100 Targets in Putin’s War Machine and Prohibits Russian Gold Imports: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated 70 new entities and individuals pursuant to Russia sanctions, including Rostec, Kamaz, defense technology holdings, industrial exporters, and management entities, as well as 29 Russian individuals. Additionally, OFAC determined that prohibitions of section 1(a)(i) of Executive Order 14068, “Prohibiting Certain Imports, Exports, and New Investment With Respect to Continued Russian Federation Aggression,” now apply to gold of Russian Federation origin, in line with actions by other G7 members. (https://home.treasury.gov/news/press-releases/jy0838;https://home.treasury.gov/system/files/126/determination_06282022_eo14068.pdf).

  • Treasury Department Issues New General Licenses: In conjunction with the new sanctions announced today, the Treasury Department announced the following new general licenses:

    o   General License 39: Permits wind-down transactions with Rostec and any entity owned 50 percent or more by Rostec through 12:01 am ET on August 11, 2022. (https://home.treasury.gov/system/files/126/russia_gl39.pdf)

    o   General License 40: Permits “all transactions ordinarily incident and necessary to the provision, exportation, or reexportation of goods, technology, or services to ensure the safety of civil aviation” to companies listed in an attached annex, so long as the aircraft is registered outside of Russia and the goods are for civil aviation purposes. The licenses has no expiration date. (https://home.treasury.gov/system/files/126/russia_gl40.pdf).

    o   General License 41: Permits “all transactions ordinarily incident and necessary to the manufacture, sale, and maintenance, including the provision and receipt of warranty and maintenance services, of agricultural equipment, components, and spare parts produced by Nefaz Publicly Traded Company (“Nefaz”) or Public Joint Stock Company Tutaev Motor Plant” and entities owned 50 percent or more by them through 12:01 am eastern on December 22, 2022. (https://home.treasury.gov/system/files/126/russia_gl41.pdf).

    o   General License 42: Permits transactions, without expiration, ordinarily incident and necessary to:

    §  “1) Requesting, receiving, utilizing, paying for, or dealing in licenses, permits, certifications, or notifications issued or registered by the Federal Security Service for the importation, distribution, or use of information technology products in the Russian Federation, provided that (i) the exportation, reexportation, or provision of any goods or technology that are subject to the Export Administration Regulations, 15 CFR parts 730 through 774, is licensed or otherwise authorized by the Department of Commerce; and

    §  (ii) the payment of any fees to the Federal Security Service for such licenses, permits, certifications, or notifications does not exceed $5,000 in any calendar year.” (https://home.treasury.gov/system/files/126/russia_gl42.pdf).

    o   General License 43: Permits divestment, debt and equity transfer, and wind down of derivative contracts involving Public Joint Stock Company Severstal, Nord Gold PLC, and any company owned 50 percent or more by those companies, through 12:01 am eastern on August 31, 2022. (https://home.treasury.gov/system/files/126/russia_gl43.pdf).

  • Key Sanctions Advisor Leaves Administration: On Saturday, Reuters reported that Deputy National Security Advisor Daleep Singh, the primary White House point of contact for sanctions on Russia, has left the administration, taking a job with PGIM Fixed Income, a Wall Street asset manager with $890 billion in assets. Singh had previously taken a leave of absence from his White House position for personal reasons. He will be replaced by former BlackRock strategist Mike Pyle. (https://www.reuters.com/world/us/uss-russia-sanctions-architect-singh-departs-ukraine-war-drags-2022-06-25/).

  • State Department Expands Visa Restrictions and Sanctions related to Rusia: Alongside the Treasury Department’s Russia-related actions, the State Department issued the following restrictions:

    o   Visa Restrictions: The Department imposed visa restrictions on 511 Russian military officers and 18 Russian nationals believed to be involved in suppressing Russian dissent.

    o   Designations Pursuant to E.O. 14024: The Department designated the Russian-installed “Mayor” of Melitopol, 45 Russian defense-related entities, 19 members of the Board of Directors of Rostec, 9 family members of Rostec Board members, three Russian military units, and an Uzbek company providing support to Russian companies attempting to evade sanctions, pursuant to Executive Order 14024. These designated individuals will have their assets blocked in the US and US persons are forbidden from transacting with them or any entity owned 50 percent or more by them. (https://www.state.gov/targeting-russias-war-machine-sanctions-evaders-military-units-credibly-implicated-in-human-rights-abuses-and-russian-federation-officials-involved-in-suppression-of-dissent/).   

  • FinCEN, BIS Issue Alert on Russian and Belarusian Export Control Evasion: On Tuesday, the Financial Crimes Enforcement Network (“FinCEN”) and the Department of Commerce’s Bureau of Industry and Security (“BIS”) issued an alert on Russian and Belarusian attempts to evade sanctions. The alert “provides financial institutions with an overview of BIS’s export restrictions to date, a list of certain commodities of concern, and other information they can use and incorporate into their risk-based screening of financial transactions. In addition, it provides select transactional and behavioral red flag indicators of export control evasion, including red flags derived from recent Bank Secrecy Act reporting.” (https://bis.doc.gov/index.php/documents/about-bis/newsroom/press-releases/3041-2022-06-28-bis-press-release-fincen-and-bis-joint-alert/file).

  • Treasury Department Announces Intent to Explore G7 Price Cap on Russian Oil: The U.S. Department of the Treasury announced that the U.S. will be working expeditiously with their G7 counterpart leaders to pursue a limit on the price of Russian oil. This advances the U.S.’s twin goals of sharply reducing Russian revenue and stabilizing global energy prices. (https://home.treasury.gov/news/press-releases/jy0837).

UPDATE:

June 27, 2022

  • White House Previews New Sanctions on Russia, Support for Ukraine: In a Monday statement, the White House announced that various federal agencies will implement the following restrictions on Russia and support measures for Ukraine:

    o   New targeted sanctions, in coordination with G7 partners, to “restrict Russia’s access to key industrial inputs, services, and technologies produced by our economies, particularly those supporting Russia’s armament industrial base and technology sector.”

    o   Explore authority to use revenues collected from tariffs on Russian goods to assist Ukraine.

    o   Efforts to reduce Russian revenues, including a prohibition on new Russian gold imports to the US and the addition of “companies engaging in backfill activities in support of Russia by adding several companies around the world to the [Department of Commerce’s] Entity List.”

    o   New sanctions on private military companies and Russian military units credibly implicated in human rights abuses in Ukraine.

    o   $7.5 billion in assistance to Ukraine in coordination with G7 partners. (https://www.whitehouse.gov/briefing-room/statements-releases/2022/06/27/fact-sheet-the-united-states-and-g7-to-take-further-action-to-support-ukraine-and-hold-the-russian-federation-accountable/).

  • Key Sanctions Advisor Leaves Administration: On Saturday, Reuters reported that Deputy National Security Advisor Daleep Singh, the primary White House point of contact for sanctions on Russia, has left the administration, taking a job with PGIM Fixed Income, a Wall Street asset manager with $890 billion in assets. Singh had previously taken a leave of absence from his White House position for personal reasons. He will be replaced by former BlackRock strategist Mike Pyle. (https://www.reuters.com/world/us/uss-russia-sanctions-architect-singh-departs-ukraine-war-drags-2022-06-25/).

  • Deputy Treasury Secretary Discusses Sanctions in Turkey: On Saturday, the Treasury Department announced that Deputy Secretary Wally Adeyemo had visited Ankara and Istanbul, Turkey from June 22-24. There, he met with representatives from the Ministry of Foreign Affairs, Ministry of Treasury and Finance, and private banking institutions. He discussed sanctions enforcement, and “all parties expressed a desire to ensure that Turkey is not used as a haven for illicit financing and that the integrity of its banking sector continues to be protected.” (https://home.treasury.gov/news/press-releases/jy0834).

UPDATE:

June 24, 2022

  • Panel Asks Treasury to Temporarily Approve Russian Swaps Trading: A panel of 13 banks and asset managers, the Credit Derivatives Determinations Committee, asked the Treasury Department to temporarily allow trades in Russian assets so that investors that wagered on a Russian default can get what they are owed. The Treasury Department’s Office of Foreign Asset Control declined to comment, and Bloomberg suspects that no action will be taken on the issue prior to the G7 Summit this weekend. (https://www.bloomberg.com/news/articles/2022-06-24/swaps-panel-asks-us-treasury-for-workaround-on-russia-sanctions).

  • Secretary of State Meets with German Representatives on Food Security Crisis: On the sidelines of the G7 Summit, Secretary of State Antony Blinken and German Foreign Minister Annalena Baerbock discussed Russia’s aggression against Ukraine and its impact on global food security. Secretary Blinken noted that the sanctions imposed on Russia collectively exempt food, food products, fertilizers, insurers, and shippers so there is no reason Russia should be contributing to the global food crisis. (https://www.state.gov/secretary-antony-j-blinken-and-german-foreign-minister-annalena-baerbock-before-their-meeting-2/).

  • Treasury Secretary Discusses Supply Chain Concerns with IMF Managing Director: During her meeting with International Monetary Fund Managing Director Kristalina Georgieva on Friday, Treasury Secretary Janet Yellen discussed the need to respond to ongoing supply chain disruptions caused by the pandemic as well as Russia’s war against Ukraine. (https://home.treasury.gov/news/press-releases/jy0833).

  • Treasury Department Reaffirms Partnership with Australia: In a call with Australia’s Treasurer Jim Chalmers, Treasury Secretary Janet Yellen thanked Australia for its strong partnership in holding Russia accountable for its invasion of Ukraine and reaffirmed the U.S. commitment to the U.S.-Australia economic partnership. (https://home.treasury.gov/news/press-releases/jy0832).

UPDATE:

June 23, 2022

  • Nike to Exit Russia: Nike told Reuters on Thursday that it is making a full exit from Russia, three months after suspending operations in the country and one month after not renewing its agreement with its largest franchisee in Russia. The company said its “priority is to ensure we are fully supporting our employees while we responsibly scale down our operations over the coming months.” (https://www.reuters.com/business/exclusive-nike-make-full-exit-russia-2022-06-23/).

UPDATE:

June 22, 2022

  • Deputy Treasury Secretary Calls for Increased Due Diligence from Global Financial Hubs: On Wednesday, Deputy Secretary of the Treasury Wally Adeyemo met with members of the United Arab Emirates Banks Federation to underscore the need for “vigilan[t] and proactive action in combatting Russian sanctions evasion.” Adeyemo specifically noted that foreign financial institutions should be mindful of OFAC’s authority to target foreign persons for providing “material support” to a sanctioned entity. (https://home.treasury.gov/news/press-releases/jy0827).

  • U.S. Encourages Countries to Import Russian Food and Fertilizer: On Wednesday, U.S. State Department Bureau of Economic and Business Affairs Assistant Secretary Ramin Toloui encouraged countries to reach out to the U.S. Treasury Department for help if they experience any problems importing food and fertilizer from Russia, noting that “The United States does not want there to be impediments to the ability of countries, companies to purchase Russian food, Russian fertilizer, and for those goods to access international markets.” (https://www.reuters.com/world/europe/us-urges-countries-reach-out-if-having-issues-with-russian-food-fertilizer-2022-06-22/).

  • Russian Disinformation a Threat to U.S. National Security: Glenn Gerstell, a senior advisor at the Center for Strategic and International Studies and former general counsel of the National Security Agency, provided insight into Russia’s use of cyberattacks and disinformation in the war with Ukraine. He noted that Russia failed to achieve a “a strategic or enduring effect” from cyberattacks but was more successful with its disinformation campaign. Gerstell said he “sees disinformation as the number one threat to U.S. national security.” (https://www.wsj.com/articles/a-perspective-on-russian-cyberattacks-and-disinformation-11655845822).

  • Microsoft Launches Russian Propaganda Index: On Wednesday, Microsoft announced additional measures to counter Russia’s successful disinformation campaign, including new analytics, additional staff, and the development of a Russian Propaganda Index that “measures user traffic to ‘Russian state-controlled and -sponsored news outlets and amplifiers’ as a proportion to traffic to all news sites.” Microsoft reported that the index showed the proportion of propaganda seen by users in Ukraine tripled in the first weeks after the invasion and rose by 86 percent in the United States. (https://www.washingtonpost.com/technology/2022/06/22/microsoft-propaganda-war-vaccines-misinformation/).

UPDATE:

June 21, 2022

  • Treasury Secretary Discusses Future Sanctions on Russia with Canadian Officials: During meetings in Toronto on Sunday with Canadian Finance Minister Chrystia Freeland, Treasury Secretary Janet Yellen said that her meetings discussed “price caps or a price exception that would enhance and strengthen recent and proposed energy restrictions by Europe, the United States, the UK and others, that would push down the price of Russian oil and depress Putin’s revenues, while allowing more oil supply to reach the global market.” (https://www.reuters.com/business/energy/us-talks-with-allies-russian-oil-price-cap-says-yellen-2022-06-20/).

  • China Pressures Tesla CEO Elon Musk for Supporting Ukraine: The Financial Times reported on increased tensions between Elon Musk and Beijing, which threaten Musk’s access to China’s consumer market. Chinese public criticism of Musk, and his company Tesla, began shortly after Musk publicly supported Ukraine and used his space exploration company SpaceX to launch satellites to secure Ukrainian internet networks after the Russian invasion. (https://www.ft.com/content/df032357-51e7-4635-baaa-f053dcc0c4c1).

UPDATE:

June 20, 2022

UPDATE:

June 19, 2022

  • Treasury Secretary Calls for Gas Tax Holiday Amid Surging Prices: In an appearance on ABC’s This Week, Treasury Secretary Janet Yellen said that a federal gas tax holiday is “an idea that’s certainly worth considering” as the conflict in Ukraine has contributed to skyrocketing gas prices. Analysts do not have consensus as to whether a federal gas tax holiday will lead to reduced gas prices, and Republicans in the Senate oppose any gas tax holiday, since proposed relief would expire shortly after the midterm elections. (https://www.wsj.com/articles/gasoline-tax-holiday-worth-considering-yellen-says-11655655086).

UPDATE:

June 17, 2022

  • U.S. Treasury Praises FATF’s Actions Against Russia: On Friday, the U.S. Treasury Department commended the actions taken by the Financial Action Task Force (FATF) at its plenary meeting to restrict Russia’s membership privileges, including removal from leadership positions and decision-making activities. The plenary meeting also yielded recommendations to prevent the misuse of digital assets.  (https://home.treasury.gov/news/press-releases/jy0823).

  • Treasury Thanks Banks for Cybersecurity Efforts After Ukraine Invasion: On Friday, Deputy Secretary of the Treasury Wally Adeyemo met with executive members of the Bank Policy Institute’s Technology Policy Division to discuss the Treasury Department’s ongoing work to promote cyber resilience, safeguard vital government applications, and work collaboratively with private sector institutions to maintain security. He thanked the participants for their steps they have taken to work with federal partners and one another on common cyber threats, given the heightened threat risk due to the Russian invasion of Ukraine. (https://home.treasury.gov/news/press-releases/jy0821).

  • CNN Discusses Inner Workings of the Treasury Department: On Friday, CNN released a detailed look at the U.S. Treasury Department’s “economic war” on Russia since Russia’s invasion into Ukraine. The report details the Department’s efforts to identify sanctions targets through its own intelligence unit, respond to oligarchs who suspect they might be the Department’s next target, and how the Department builds its programs to have maximum effect over time. (https://www.cnn.com/2022/06/17/politics/nerd-warriors-treasury-department-sanctions-economic-war-russia/index.html).

UPDATE:

June 16, 2022

  • Department of Commerce Denies Export Privileges for Belarusian Airlines: On Thursday, the Department of Commerce’s Bureau of Industry and Security (“BIS”) issued an order temporarily denying all export privileges for Belavia Belarusian Airlines (Belavia), the flag carrier of Belarus, due to ongoing violations of the comprehensive export controls imposed on Belarus by the Commerce Department. This is the first action BIS has taken against a Belarusian airline under its new export controls. (https://bis.doc.gov/index.php/documents/about-bis/newsroom/press-releases/3029-2022-06-16-bis-press-release-belavia-tdo/file).

  • US Prosecutors Move to Freeze $5.3 Million in Oligarch’s Assets: On Wednesday, federal prosecutors in New York announced that they were moving to seize more than $5.3 million from a US bank account owned by sanctioned oligarch Konstantin Malofeyev. Malofeyev was the target of OFAC sanctions announced on April 20, though he was previously sanctioned in 2014. (https://www.cnn.com/2022/06/16/politics/russian-oligarch-konstantin-malofeyev/index.html).

  • Treasury Secretary Praises Banks for Sanctions Partnership: In a Thursday meeting with CEO Members of the Board of Directors of the Bank Policy Institute, Treasury Secretary Janet Yellen outlined the efforts the Treasury Department has made to impose sanctions on Russia for its invasion of Ukraine. She praised banks for their “strong partnership that financial institutions have had with Treasury to implement historic sanctions and to protect financial institutions from cyber threats.” (https://home.treasury.gov/news/press-releases/jy0820).

UPDATE:

June 15, 2022

  • U.S. Imposes Sanctions on Members of Russian Violent Extremist Group: On Wednesday, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) imposed sanctions on supporters of the Russian Imperial Movement (“RIM”), was previously designated by the U.S. Department of State as a Specially Designated Global Terrorist (“SDGT”) organization on April 7, 2020 for having provided training for acts of terrorism. (https://home.treasury.gov/news/press-releases/jy0817).

  • U.S. Ambassador to Ukraine Meets with Ukrainian Cybersecurity Officials: On Wednesday, U.S. Ambassador to Ukraine Bridget Brink met with the Ukrainian government’s main cybersecurity agency Wednesday and pledged support for Kyiv’s “crucial work” in defending against Russian hacking threats. The meeting discussed a four-year, $38 million U.S. Agency for International Development (“USAID”) program aimed at bolstering Ukraine’s cyber defenses, according to Brink and Ukrainian officials. (https://www.cnn.com/europe/live-news/russia-ukraine-war-news-06-15-22/h_483bbad7e212d9f0a9272f80d4722ed1).

UPDATE:

June 14, 2022

  • OFAC Issues General License Extending Authorization for Certain Energy Related Transactions: On Tuesday, OFAC released General License 8C, which extends the license for energy related transactions through December 5, 2022. The General License replaces General License 8B, which permitted certain energy related transactions with Sberbank, VTB Bank, Alfa Bank, Vneshcombank, Otkritie, Sovcombank, any bank owned 50% or more by any of these entities, and the Russian Central Bank. General License 8B was set to expire on June 24. OFAC also released administrative updates to several FAQs to reflect the extended deadline. (https://home.treasury.gov/system/files/126/russia_gl8c.pdf; https://home.treasury.gov/policy-issues/financial-sanctions/faqs/updated/2022-06-14).

  • PIMCO Warns Treasury of Sanctions’ Impact on U.S. Pension Funds: Executives at Pacific Investment Management Co. (PIMCO), have warned U.S. Treasury officials about the potential losses U.S. pension funds will face if fund managers are forced to write down their Russian holdings. The executives have also stressed that a Russian default would allow President Putin to keep foreign currency reserves that would otherwise have been paid to creditors—a potentially lucrative source of funding for the war effort. (https://www.bloomberg.com/news/articles/2022-06-14/pimco-warned-us-treasury-that-russia-sanctions-will-hit-pensions).

  • Deputy Treasury Secretary Discusses Expanded Funding for Sanctions Enforcement: In prepared remarks before the Senate Appropriations Subcommittee on Financial Services and General Government, Deputy Treasury Secretary Wally Adeyemo discussed how the war in Ukraine has impacted the Treasury Department’s budget. After explaining the vastly expanded sanctions program, Deputy Secretary Adeyemo noted that the “President’s FY 2023 request includes a $49 million increase in funding for FinCEN to add some of the personnel required to implement the Anti-Money Laundering Act and the Corporate Transparency Act and to continue to build the systems we need to track beneficial ownership and leverage that information to pursue critical national security objectives.” He also discussed enhanced cybersecurity measures to enhance classified information systems needed for sanctions enforcement. (https://home.treasury.gov/news/press-releases/jy0815).

UPDATE:

June 13, 2022

  • US Officials Warn Against Diversion of Aid for Ukraine: On Monday, The Wall Street Journal published an article summarizing comments from members of Congress calling for increased transparency and oversight of funds headed to Ukraine. Though no reports of malfeasance have yet emerged, Senator Chuck Grassley (R-IA) has sent letters to the State Department, USAID and Defense Department to closely review aid to Ukraine, Senator Rand Paul (R-KY) pushed to include oversight provisions in the initial $40 billion aid package, and Senator John Kennedy (R-LA) has introduced standalone legislation implementing a special inspector general for Ukraine. (https://www.wsj.com/articles/with-billions-going-to-ukraine-officials-warn-of-potential-for-fraud-waste-11655121601).

UPDATE:

June 11, 2022

  • Biden Administration Focused on Seizing Oligarch Assets for Ukraine Reparations, not Central Bank Assets: On Saturday, The Wall Street Journal published a survey of the US response to calls to use frozen Russian Central Bank assets to pay reparations to Ukraine. The prevailing position was best summarized by the National Security Council, which said Friday the administration seeks to ease the seizure of oligarchs’ assets “directly obtained from corrupt dealings with the Russian government” and to enable the departments of Justice, Treasury and State to use those funds “to remediate harms of Russian aggression toward Ukraine.” Legal experts surveyed said there may be legal avenues to seize central bank assets, but those efforts must be coordinated multilaterally for maximum legitimacy. (https://www.wsj.com/articles/effort-to-force-russia-to-pay-reparations-to-ukraine-faces-uphill-battle-11654939800?mod=hp_lead_pos4).

UPDATE:

June 9, 2022

  • OFAC Issues New FAQs Related to May 8 Directive: On Thursday, OFAC Released the following FAQs related to the May 8 directive banning the provision of certain accounting, trust and corporate formation, and management consulting services to Russia (https://home.treasury.gov/policy-issues/financial-sanctions/faqs/added/2022-06-09):

    o   FAQ 14072 states that the directive blocks the provision of tax preparation and filing services to any person located in the Russian Federation. This ban does not apply to the export, reexport, sale, or supply, directly or indirectly, of tax preparation-related software to the Russian Federation.

    o   FAQ 1067 further clarifies that the directive does not prevent the export, reexport, sale, or supply, directly or indirectly, software to the Russian Federation, along with any service associated with the export of such software, like engineering and design, as long as those services do not fall in the definition of management consulting.

    o   FAQ 1066 states that online university courses on accounting, management consulting services, trusts, or corporate formation are permitted, as long as they do not evade the underlying ban on provision of those services to the Russian Federation.

    o   FAQ 1065 states that US persons are prohibited from serving as voting trustees on behalf of or for shares of person located in Russia.

    o   FAQ 1064 states that executive search and vetting services are included in the definition of management consulting and therefore banned under the directive.

    o   FAQ 1063 states that the provision of restricted services to existing companies in Russia are included in the ban.

    o   FAQ 1062 states that a US person working at the US subsidiary of a Russian company may not provide any of the restricted services to the Russian parent company.

    o   FAQ 1061 states that US persons may still work as employees of entities located in Russia, so long as they do not provide any of the restricted services to the company.

    o   FAQ 1060 states that US persons may serve on the board of directors of a company located in the Russian Federation, but would prohibit US persons from providing nominee officer or director services in which a U.S. person is contracted to serve as a nominee officer, director, shareholder, or signatory of a legal person on behalf of a person located in the Russian Federation.

    o   FAQ 1059 states that the directive does not prohibit the provisions of services to a non-Russian company that has a physical presence and operations outside of the Russian Federation, even if the company is owned or controlled by Russian entities, so long as the service is not further exported or reexported to individuals in Russia.

    o   FAQ 1058 defines “person located in the Russian Federation” to “include persons in the Russian Federation, individuals ordinarily resident in the Russian Federation, and entities incorporated or organized under the laws of the Russian Federation or any jurisdiction within the Russian Federation.” 

  • U.S. and Europe Seek to Lower Gas Prices:  The Wall Street Journal reported Thursday that the U.S. and its allies are working closely to limit further surges in gas prices while at the same time, attempting to cut off revenues to Russia as it increases its oil exports to other regions of the world. One idea under consideration by the G7 is to allow insurers to only cover shipments of Russian oil to non-European countries that fall under a certain price cap. (https://www.wsj.com/articles/u-s-european-allies-try-to-restrain-global-oil-prices-11654767002).

UPDATE:

June 8, 2022

  •  Impact of Russian Sanctions on Ransomware Attacks Uncertain: On Tuesday, The Wall Street Journal reported on the unclear impact of sanctions against the ransomware attacks. The U.S. Department of Treasury has released sanctions targeting the financial infrastructure that supports ransomware attacks. Cybersecurity experts note that despite success minimizing the use of money laundering tools, the effect of sanctions to reduce cyberattacks broadly is uncertain. (https://www.wsj.com/articles/sanctions-take-toll-on-laundering-tools-used-by-ransomware-gangs-11654637128).

  • Biden Administration Conflicted on Possible Sanctions Waiver for Belarus Fertilizer Industry In Response to Food Crisis: On Tuesday, The Wall Street Journal published a report detailing the divide within the Biden Administration on how to address the food crisis from Russia’s war in Ukraine. The main source of division is over a proposal for a six-month waiver of sanctions on Belarus’s potash fertilizer industry. According to the report, the State Department is against lifting sanctions while the White House’s National Security Council supports considering the proposal. (https://www.wsj.com/articles/looming-food-crisis-related-to-ukraine-war-divides-biden-administration-11654639588).

  •  US and Six Allies Announce Resumption of Participation in Arctic Council Activities That Do Not Involve Russia: On Wednesday, the U.S. State Department released a joint statement with Canada, Denmark, Finland, Iceland, Norway, Sweden announcing the limited resumption of projects in the Arctic Council that do not involve Russia. Involvement by the U.S. and others has been on hold since March 3. (https://www.state.gov/joint-statement-on-limited-resumption-of-arctic-council-cooperation/).

UPDATE:

June 7, 2022

  • OFAC Issues Clarifying Guidance on “New Investment” Ban:   OFAC provided Frequently Asked Questions about the U.S. sanctions regime: (https://home.treasury.gov/policy-issues/financial-sanctions/faqs/added/2022-06-06).  OFAC addresses a number of issues in the guidance, including but not limited to:

    o   Defining “new investment” broadly to include a commitment of capital or other assets for the purpose of generating returns or appreciation made after the effective date of the Executive Order, including those pursuant to an agreement entered into before the Executive Order.  (FAQ 1049).

    o   “Maintenance” and “Divestment”-Related Exclusions – OFAC recognizes certain limited exclusions relating to “maintenance” of pre-existing operations and contractual commitments, and of “divestment”, each subject to several important conditions and fact-specific limitations.  (FAQs 1050, 1051, 1052 and 1053). 

    o   Potential Reach to Dealings Outside Russia –  The guidance reflects that the reach of the new investment ban can expand to transactions outside Russia under certain circumstances.  In addressing debt and equity transactions involving entities located outside the Russian Federation, OFAC states that the ban on new investment in Russia would not extend to such transactions “provided that” (i) such funds are not specifically intended for new projects or operations in the Russian Federation and (ii) the revenues of the entity located outside the Russian Federation are not predominantly derived from its investments in the Russian Federation.  (FAQ 1055).

    o   Purchase of Debt and Equity Securities – Notably, OFAC’s guidance reflects expansive positions relating to debt and equity securities issued by an entity in the Russian Federation in several respects.  The guidance confirms that US Persons may not purchase new or existing debt and equity securities issued by an entity in Russia, whether or not sanctioned.  This supplements and expands previous restrictions involving equity and debt restrictions, including secondary market transactions involving sovereign debt and raises certain interpretive issues for holders of such debt in an event of default.   The guidance also confirms the ban could also be implicated in the context of funds with holdings that include Russian debt or equity securities investments, at least where the holdings represent “a predominant share by value”.  (FAQs 1054 and amended FAQ 1005).

  • Treasury Secretary Says Inflation Here to Stay, Blames Russian Invasion: At a Senate Finance Committee meeting on Tuesday, Treasury Secretary Janet Yellen told lawmakers that “[t]here’s no question that we have huge inflation pressures, that inflation is really our top economic problem at this point and that it’s critical we address it.” She added that, “Putin’s war in Ukraine is having impacts on energy and food prices globally,” and that it is “virtually impossible for us to insulate ourselves.” (https://www.bloomberg.com/news/articles/2022-06-07/yellen-defends-biden-spending-as-she-acknowledges-inflation-woes).

UPDATE:

June 6, 2022

UPDATE:

June 4, 2022

  • Chevron CEO Says Russia Still Able to Export Oil: In a meeting with The Wall Street Journal this week, Chevron CEO Mike Wirth stated that Russia is still exporting oil despite increasing sanctions on the country, but noted that the departure of Western oil companies from the country will reduce production numbers. He compared the situation in Russia to the one in Iran and Venezuela, where production eroded over time. Wirth stated that Saudi Arabia has excess capacity to make up for any losses in Russian production. (https://www.wsj.com/articles/chevron-ceo-sees-russian-oil-output-falling-after-exit-of-western-firms-11654344001?mod=hp_lista_pos1).

  • US Skeptical that UN-Led Talks Will Lead to Ukrainian Grain Exports: Speaking toPolitico on Sunday, unnamed US government officials stated that they were not optimistic that UN-led negotiations with Russia will lead to increased grain exports from Ukraine. The officials said that Russia’s insistence on sanctions relief in exchange for grain exports was not an option, and doubted that UN negotiators would get Russia to change its position. (https://www.politico.com/news/2022/06/05/un-russia-ukraine-grain-00037240).

UPDATE:

June 3, 2022

  • Department of Justice Official Discusses Work of KleptoCapture Task Force:  In an interview with Politico Thursday, Director of the KleptoCapture Task Force at DOJ, Andrew Adams, highlighted the role of international partners in effectuating U.S. and European sanctions on Russian nationals. He also noted that he hoped DOJ would create a “permanent [ ] clearinghouse for thinking about sanctions,” adding that, “A major part of the work in the first several months of the task force has been coordination, and coordination of foreign partners and essentially giving them an outlet to plug into for their own efforts. Going forward that should, that can, exist, and I think people understand that that should just exist as easy as plug and play for the next kind of crisis that exists in this space.” (https://www.politico.com/newsletters/national-security-daily/2022/06/02/kleptocapture-is-about-more-than-russian-yachts-00036743).

  • BIS Issues New Russia/Belarus Export Control Updates, Updates Enforcement Procedures: On Thursday, June 2, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a new rule updating Russia and Belarus export controls and making changes to its enforcement procedures, including the following:

     

    o   Extending license requirements for Russian and Belarussian military end uses and military end users to previously excluded EAR99 food and medicine items, and corresponding adjustments to Russian and Belarusian military end users on the Entity List. License applications will be subject to case by case review.

    o   Revised EAR restrictions for items destined for certain regions of Ukraine, including new categories of transactions subject to case-by-case review.

    o   Clarifications to the Russia Industry Sector Sanctions Rule, including Supplements 2 and 4.

    o   Amending the EAR to make charging letters publicly available in future export enforcement cases prior to the final administrative disposition of such cases to allow BIS to heighten awareness of ongoing proceedings and export enforcement. (https://public-inspection.federalregister.gov/2022-11885.pdf).

  • U.S. DOJ Official Highlights Indictments of Russian Hackers:  In remarks before the NATO Cooperative Cyber Defense Center of Excellence, Assistant Attorney General for National Security Matthew Olson noted that the DOJ is “particularly focused right now on the cyber threat from Russia, and we are bracing for the possibility of more attacks.” He also emphasized DOJ’s “all tools” approach, noting that it will “continue to aggressively investigate and prosecute individuals for malicious cyber activity,” including Russian nationals. (https://www.justice.gov/opa/speech/assistant-attorney-general-national-security-matthew-g-olsen-delivers-remarks-nato).

UPDATE:

June 2, 2022

  • Treasury Imposes Additional Sanctions on Russian Elites: On Thursday, Treasury Department added over thirty new names to the Specially Designated Nationals (SDN) list targeting assets and individuals used by Russian President Vladimir Putin to evade U.S. sanctions. The sanctions target several yachts and private jets linked to Russian oligarchs, a yacht brokerage with ties to the Kremlin, Russian government officials, and Putin’s financial custodian and close friend Sergei Roldugin. (https://home.treasury.gov/news/press-releases/jy0802).

  • State Department Adds Further Designations of Russian Oligarchs and Elites, Close Family Members and Affiliated Entities.  In coordination with the Treasury Department, the State Department also added several designations which will in turn be added to Treasury’s SDN List.  The additions include eight individuals, including Foreign Ministry Spokeswoman Maria Zakharova and prominent oligarch Alexey Mordashov and his family. In addition, the State Department designated four of Mordashov’s companies, Severgroup, Severstal, Algoritm, and Nord Gold. All designated individuals will be added to the SDN list. (https://www.state.gov/promoting-accountability-and-imposing-costs-on-the-russian-federation-and-its-enablers-for-putins-aggression-against-ukraine/).

     

  • Treasury Issues Four General Licenses Related to the New Sanctions: The Treasury Department issued four Russia-related General Licenses consistent with the newly imposed sanctions from the Treasury and State Departments:

    o   General License 25B adds Algoritm as an unauthorized party for transactions related to telecommunications and certain internet-based communications; 

    o   General License 36 authorizes the wind down of transactions involving Severstal and any entity owned 50 percent or more, directly or indirectly, by Severstal through 12:01am est on August 31, 2022;

    o   General License 37 authorizes the wind down of transactions involving Nord Gold and any entity owned 50 percent or more, directly or indirectly, by Nord Gold through 12:01am est on July 1, 2022; and

    o   General License 38 authorizes transactions related to pension payments to U.S. persons that are otherwise blocked by E.O. 14024. 

     

  • Secretary of State Blinken Discusses Ukraine with UK Foreign Secretary Truss: In a call with UK Foreign Secretary Elizabeth Truss on Thursday, Secretary of State Anthony Blinken spoke to the importance of transatlantic unity against Russian aggression and the need to ensure vital agricultural commodities can leave Ukraine to provide the world critical food supplies. (https://www.state.gov/secretary-blinkens-call-with-uk-foreign-secretary-truss-8/).

UPDATE:

June 1, 2022

  • Fractures Emerge Within the Biden Administration Over Potential Russian Energy Sector Sancfions: Bloomberg reported Wednesday that the Biden Administration is divided in its efforts to punish Russia for the invasion of Ukraine. One faction, led by officials in the State Department and White House are urging the President to impose secondary sanctions on Russian oil exports. Another, comprised by officials at the Treasury Department, are urging the President to impose a cap on oil prices in order to allow countries to buy Russian energy while limiting its revenues at the same time.  (https://www.bloomberg.com/news/articles/2022-06-01/us-wavers-over-next-russia-sanctions-as-fears-of-divide-grow).

  • U.S. Taskforce Zeroes In on Oligarchs’ Assets:The New York Times reported Wednesday that KleptoCapture, a multi-agency investigative taskforce has begun gathering evidence to disrupt and prosecute businesses and individuals who knowingly assisted Russian individuals’ efforts to evade U.S. sanctions. The Report noted that the U.S. is working alongside investigators from Europe to uncover the ownership behind the networks of shell companies listed as owning superyachts, Italian villas, and the like. (https://www.nytimes.com/2022/06/01/world/europe/russia-oligarchs-yachts-middlemen.html)

     

UPDATE:

May 31, 2022

  • Debate Within Biden Administration About Seizing Russian Assets to Help Ukraine: Amid increased global calls for seizure of sanctioned Russian assets, including support from some EU member states, discussion at the G7, and Congressional proposals, Biden administration officials are debating how to find a common ground with the EU on a seizure of certain sanctioned Russian funds (including Russian Central Bank funds) and possible ramifications (including the legality under US law and the risk of other countries putting their central bank reserves in non-US Dollar currencies). Canada is also considering similar measures.  (https://www.nytimes.com/2022/05/31/us/politics/russia-sanctions-central-bank-assets.html).

     

UPDATE:

May 30, 2022

UPDATE:

May 29, 2022

UPDATE:

May 27, 2022

  • Treasury Sanctions Russian Banks for Facilitating Payments for North Korea: On Friday, the Treasury Department added new names to the Specially Designated Nationals list in connection with new missile activity in North Korea. Two of the new designations are for the Far Eastern Bank and Bank Sputnik, two Russian banks that facilitated payments on behalf of North Korean entities. (https://home.treasury.gov/news/press-releases/jy0801).

  • Secretary of State Blinken Calls Ukrainian Counterpart: On Friday, Secretary of State Antony Blinken called Ukrainian Foreign Minister Dmytro Kuleba for the second time this week. The pair discussed food security issues stemming from the conflict in Ukraine, and Secretary Blinken stated that the US and its allies will continue to support Ukraine through the crisis and its consequences. (https://www.state.gov/secretary-blinkens-call-with-ukrainian-foreign-minister-kuleba-24/).

  • House Foreign Affairs Committee Chairman in Europe to Discuss Black Sea Blockade: During meetings in Europe this week, House Foreign Affairs Committee Chairman Gregory Meeks (D-NY) spoke to various officials on the issue of food security emanating from the conflict in Ukraine. He stated that the blockade and restricted food exports are contributing to starvation and increases in food prices worldwide. (https://thegrio.com/2022/05/27/white-house-sanctions-russia-grains-food-shortages/).

UPDATE:

May 26, 2022

  • US Rules Out Sanctions Relief for Russia in Exchange for Grain Exports: Speaking on Thursday, State Department Spokesman Ned Price ruled out sanctions relief in exchange for grain exports from Ukraine and Russia, saying, “I think we have – all have good reason to be skeptical when we hear various pledges and offers from Russia.” (https://news.yahoo.com/us-rules-lifting-russia-sanctions-093300132.html).  

  • Secretary of State Blinken Criticizes China’s Ties with Russia: In a speech on Thursday outlining the administration’s China policy, Secretary of State Antony Blinken criticized recent meetings between Chinese President Xi Jinping and Russian President Vladimir Putin, saying “Beijing’s defense of President Putin’s war to erase Ukraine’s sovereignty and secure a sphere of influence in Europe should raise alarm bells for all of us who call the Indo-Pacific region home.” (https://www.state.gov/the-administrations-approach-to-the-peoples-republic-of-china/).

  • Treasury Sanctions Iranian Groups with Russian Ties: In sanctioning 10 people from four countries and nine companies on Wednesday, the Treasury Department took action against an international oil smuggling and money laundering network led by the Islamic Revolutionary Guard Corps and Qods Force. The ring has deep ties in Russia, according to the release. Two of the sanctioned individuals were Kamaluddin Gulam Nabizada, a former Afghanistan ministry official in Moscow, who is accused of raising money for the IRGC-QF with the help of senior Russian government and intelligence officials, and his associate, Mihrab Suhrab Hamidi, who specializes in oil trades. (https://www.upi.com/Top_News/US/2022/05/26/sanctions-Iran-oil-smuggling-network/6351653535986/).

  •  Energy Secretary Says Russia “Weaponizing” Energy: While speaking at a General Electric facility on Thursday, Energy Secretary Jennifer Granholm said that Russia is “weaponizing energy, which is another reason why as a nation, we should move to energy sources that cannot be weaponized.” She cited recent gas shutoffs in Poland and Finland as proof of this trend. The remainder of her speech focused on domestic energy production. (https://www.cnn.com/2022/05/26/business/russia-oil-gas-ukraine-granholm/index.html).

UPDATE:

May 25, 2022

  • Treasury Department Extends Russia General License 13A: On Wednesday, the Treasury Department issued General License 13A, which permits US persons to pay taxes, fees, or import duties, and purchase or receive permits, licenses, registrations, or certifications, regardless of whether these transactions violate restrictions on payments with the Russian Central Bank, National Wealth Fund, and Ministry of Finance. The new license is valid until 12:01am on September 30, 2022. (https://home.treasury.gov/system/files/126/russia_gl13a.pdf).

  • Treasury Official Outlines Russia Sanctions Program at Anti-Money Laundering Conference:Speaking on Wednesday at SIFMA’s Anti-Money Laundering and Financial Crimes Conference, Under Secretary of the Treasury for Terrorism and Financial Intelligence of the United States Brian Nelson discussed the Treasury Department’s efforts to sanction Russia. He stated that the measures to date are intended to hinder the Russian economy, notably the defense sector, and to improve enforcement. He thanked the private sector for their partnership in this effort, highlighting the Department’s guidance, outreach, and enforcement measures as ways to inform the public. (https://home.treasury.gov/news/press-releases/jy0800).

  • Nike Leaving Russian Market: On Wednesday, Nike announced that it would not extend its franchise agreement with Russia’s Inventive Retail Group (“IRG”) the largest retailer of Nike products in the country. The stores will close once all goods are sold. Nike previously suspended online sales in Russia and closed all of its shops, including ones operating under franchise agreements, in the country. (https://www.rferl.org/a/nike-marks-spencer-leave-russia-ukraine-war/31867200.html).

UPDATE:

May 24, 2022

  • Treasury Declines to Renew Russian Sovereign Debt License: On Tuesday, the Treasury Department announced that it would not extend General License 9C, which permits US persons to process interest payments on Russian sovereign debt held with the Russian central bank, the national wealth fund of the Russian Federation, or the Russian Ministry of Finance. The license also permitted other wind-down activity related to debt held at the following Russian banks: Vneshcombank, Bank Otkritie, Sovcombank, Sberbank, VTB, or any entity owned 50 percent or more by any of those entities. The license for these transactions was set to expire tomorrow, though several reports indicated that the Department was unlikely to renew the license. The move increases the likelihood that Russia will default on its debt. (https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220524_33;https://www.nytimes.com/2022/05/24/us/politics/russian-debt-treasury.html).

  • Secretary of State Discusses Food Security with Ukrainian Counterpart: On Tuesday, Secretary of State Antony Blinken called his Ukrainian counterpart, Dmytro Kuleba. The two discussed ongoing diplomatic efforts related to the war in Ukraine, including food security issues related to the conflict. The two also discussed the recently passed $40 billion assistance package that Congress approved for Ukraine. (https://www.state.gov/secretary-blinkens-call-with-ukrainian-foreign-minister-kuleba-23/).

UPDATE:

May 23, 2022

UPDATE:

May 22, 2022

  • YouTube Blocks Pro-Invasion Content: On Sunday, YouTube announced that it had removed 9,000 channels and 70,000 individual videos for a violation of YouTube’s major violent events policy. YouTube did not provide a breakdown by topic of reviewed videos, but YouTube’s Chief Product Officer Neal Mohan said, “I don’t have the specific numbers, but you can imagine a lot of it being the narratives that are coming from Russian government, or Russian actors on behalf of the Russian government.” (https://www.theguardian.com/technology/2022/may/22/youtube-ukraine-invasion-russia-video-removals).

  • American Companies Operating in Russia Face Legal And Practical Landmines: On Friday, The New York Times published an article profiling US steel company Arconic, whose facility in Samara, Russia remains open. The company’s predicament illustrates a larger concern: sanctions on Russia have made it difficult for the company to continue operating (though there is no indication that Arconic is operating in violation of US sanctions itself), but if it suspends operations in Russia due to sanctions, it risks liability under new Russian laws. (https://www.nytimes.com/2022/05/20/world/europe/russia-ukraine-arconic-samara.html).

UPDATE:

May 20, 2022

  • BIS Issues Temporary Denial Order Against Fifth Russian Airline, Names Plane in Violation of Export Controls: On Friday, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) announced an order denying export privileges for Rossiya Airlines, the fifth Russian airline to receive such a designation from the office. The Temporary Denial Order suspends Rossiya Airlines’ rights to participate in transactions subject to the Export Administration Regulations (“EAR”), and will remain in place for 180 days, subject to renewal. BIS also publicly identified a 787 Dreamliner owned by Russian oligarch Roman Abramovich as an aircraft in likely violation of US export controls, the second plane owned by Abramovich to receive the designation. The notification alerts the public that any form of service to the aircraft subject to the EAR will require US government authorization. (https://www.bis.doc.gov/index.php/documents/about-bis/newsroom/press-releases/2994-2022-05-20-press-release-bis-rossiya-tdo-and-list-update-final/file).

  • President Biden to Sign Ukraine Assistance Bill During Trip to Asia: National Security Council staff confirmed to CNN on Friday that President Biden intends to sign the recently-passed $40 billion Ukraine assistance package into law during his trip to Asia this week. The Senate passed the legislation on Thursday, after the President and his delegation had already departed for Korea; the bill will be flown to Korea with a person who was already traveling to the region for their official duties. (https://www.cnn.com/europe/live-news/russia-ukraine-war-news-05-20-22/h_7d77e8ea071145ebe3f241334a553418).

UPDATE:

May 19, 2022

  • McDonald’s Finds Buyer for Russian Business License: In keeping with its announcement to end Russian business earlier in the week, McDonald’s stated on Thursday that it had agreed to sell its Russian business license to Alexander Govor, an existing McDonald’s licensee. Financial terms were not disclosed, but the agreement requires McDonald’s to retain employees for at least two years on equivalent terms and fund corporate salaries until closing. The new company cannot use McDonald’s branding or menus. (https://www.wsj.com/articles/mcdonalds-to-sell-russian-business-to-licensee-11652963542?mod=livecoverage_web).

UPDATE:

May 18, 2022

  • Treasury Secretary Expresses Preference to Let Russian Debt License Expire: Speaking at a press conference in Bonn, Germany on Wednesday, Treasury Secretary Janet Yellen was asked about recent reports regarding negotiations at the Department on allowing General License 9A, which permits US persons to collect Russian sovereign debt payments, to expire. She stated, “The expectation was that it was time limited. So, I think it’s reasonably likely that the license will be allowed to expire. There has not been a final decision on that. But I think it’s unlikely that it would, you know, it would continue.” (https://home.treasury.gov/news/press-releases/jy0793).

UPDATE:

May 17, 2022

  •  US Reportedly Letting Russian Sovereign Debt License Expire: Sources at the Treasury Department told Bloomberg on Tuesday that they plan to let General License 9A, which permitted US persons to receive payments from the Russian Central Bank for repayment of sovereign debt obligations, to expire. Though the move is not final, it would significantly hinder Russia’s ability to pay its sovereign debts. The next round of Russian debt payments are due on May 26; the country narrowly escaped default earlier this month. (https://www.bloomberg.com/news/articles/2022-05-17/us-set-to-block-russian-debt-payments-raising-odds-of-default).

  • Commerce Department Enforcememt Official Discusses Enforcement of Russia Sanctions: During a speech to the Society for International Affairs on Monday, Assistant Secretary of Commerce for Export Enforcement Matt Axelrod discussed efforts already taken to sanction Russia, and the Department’s intended next steps. After summarizing enforcement actions under the new Russia sanctions to date, he discussed future restrictions, saying that the Department would be changing its policies on administrative enforcement in order to ensure compliance with the new export control laws. His proposed reforms included publicizing charging letters, reconsidering use of no admit/no deny settlements, and increasing penalty amounts. (https://www.bis.doc.gov/index.php/documents/about-bis/newsroom/press-releases/2992-2022-05-16-remarks-as-axelrod-to-sia/file).

  • Treasury Department to Ease Sanctions on Venezuela, Allowing European Companies to Export Venezuelan Energy Products: On Tuesday, Bloomberg reported that the Treasury Department plans to reduce sanctions on Venezuela, which will allow European companies operating in Venezuela to divert Venezuelan oil to the EU. Major oil producer Chevron will also be allowed to negotiate a resumption of operations in the country. The move is likely an effort to ease the pain of impending restrictions on EU imports of Russian oil. (https://www.bloomberg.com/news/articles/2022-05-17/us-to-lift-some-sanctions-on-venezuelan-oil-ease-chevron-talks).

  • Treasury Secretary Praises European Efforts to Restrict Russian Energy Imports During Trip to Brussels: On Tuesday, Secretary of the Treasury Janet Yellen visited Brussels, where she met with European Commission President Ursula von der Leyen, as well as European Commission Executive Vice President Valdis Dombrovskis and European Commissioner for the Economy Paolo Gentiloni. She also spoke at the Brussels Economic Forum, where she praised EU efforts to reduce dependence on Russian oil, saying “I know that Europe is facing a uniquely difficult situation, given existing infrastructure and supply contracts with Russia over the near term.  That is why I commend European leaders for their proposal to phase out all Russian energy supplies within six months.” She added that the conflict indicates that the EU and US should rely on allies, not Russia and China, for sourcing raw materials. (https://home.treasury.gov/news/press-releases/jy0789;https://home.treasury.gov/news/press-releases/jy0789).

  •  Ukraine Aid Bill Clears Senate Procedural Hurdle: On Monday evening, the Senate voted to advance the $40 billion assistance package for Ukraine passed by the House by a vote of 81-11. All 11 votes against the bill came from Republicans concerned about increased government spending. Senate leadership expects a final vote on the legislation later this week. (https://news.yahoo.com/11-republican-senators-vote-against-232243255.html).

  •  Commerce Department Confirms Reduction in Chinese Exports to Russia: Speaking to Commerce Secretary Gina Raimondo, The Washington Post confirmed export figures first reported by The Wall Street Journal indicating that Chinese exports of laptops to Russia fell by 40 percent in March, and Chinese exports of telecommunications network equipment to Russia fell by 98 percent in March. The Secretary said that these figures indicate the success of US export control programs. (https://www.washingtonpost.com/world/2022/05/17/china-russia-tech-exports/).

UPDATE:

May 16, 2022

  • US-EU Trade and Technology Council Joint Statement Highlights Export Controls, Supply Chain Security: On Monday, the US-EU Trade and Technology Council released a joint statement from US and EU parties on their recent meeting. Among other items, the parties committed to “build on and enhance…collaboration” on controls on exports to Russia, and to “develop a common early warning and monitoring mechanism on semiconductor value chains” due to supply chain disruptions as a result of the invasion of Ukraine. The joint statement also demonstrates a commitment to further investment in Ukraine. (https://ec.europa.eu/commission/presscorner/detail/en/ip_22_3034).

  • Treasury Secretary Visits Poland: From May 14 to 16, Treasury Secretary Janet Yellen visited Poland. The Secretary met with Polish Prime Minister Mateusz Morawiecki, Finance Minister Magdalena Rzeczkowska and Governor of Narodowy Bank Polski Adam Glapiński during her visit. She welcomed the country’s leadership in holding Russia accountable for its invasion of Ukraine, and also promoted international efforts to combat rising food insecurity as a result of the invasion of Ukraine. (https://home.treasury.gov/news/press-releases/jy0786; https://home.treasury.gov/news/press-releases/jy0783).

  • McDonalds Selling Russian Business: On Monday, McDonalds announced that it was selling all business units and restaurants in Russia; it had previously temporarily closed all business operations in Russia. After the sale to a local buyer, the restaurants will no longer use the McDonalds name, logo, branding, or menu. In connection with the exit, McDonald’s said it expects to record an accounting charge of between $1.2 billion and $1.4 billion, and recognize a significant foreign currency translation loss. (https://www.wsj.com/articles/mcdonalds-to-exit-from-russia-11652697074).

UPDATE:

May 15, 2022

  • Support Builds for Enhanced Sanctions on Russian Gold, Diamonds: Though the US has already imposed sanctions on Russian diamond company Alrosa, jewelry made with Russian diamonds and gold is still entering the US after it is further processed in other countries. Members of Congress like Elissa Slotkin (D-MI) are organizing bipartisan letters to the Treasury Department to close this loophole, and private companies like Tiffany and Signet are independently investigating their supply chains and publicly committing to not use Russian diamonds. Jewelers with tighter profit margins may have difficulty in implementing these measures, as gold with a fully traceable supply chain, for example, can cost 20 percent more than other gold. (https://www.wsj.com/articles/why-its-so-hard-to-keep-russian-diamonds-and-gold-out-of-the-u-s-despite-sanctions-11652526180?mod=hp_lead_pos2).

  • Senate Minority Leader Supports Designating Russia as a State Sponsor of Terrorism: During remarks in Stockholm, Sweden on Sunday, Senate Minority Leader Mitch McConnell (R-KY) said that he supported designating Russia as a state sponsor of terrorism, saying “The president could do it on his own, and I would urge him to do it.” He also called on the Senate to quickly pass a $40 billion package of military assistance to Ukraine. Senator McConnell recently visited Kyiv and met with Ukrainian President Volodymyr Zelenskyy, along with Senators John Barasso (R-WY), Susan Collins (R-ME), and John Cornyn (R-TX). (https://thehill.com/news/senate/3489027-mcconnell-urges-biden-to-name-russia-a-state-sponsor-of-terrorism/).

  • Secretary of State Says NATO Prepared to Continue Sanctions “As Long As Necessary”:During press availability before meetings with NATO foreign ministers on Sunday, Secretary of State Antony Blinken said, “Every member of the Alliance wants to bring this war to an end as soon as possible, but we’re equally determined to maintain our security assistance to Ukraine, to continue our sanctions, export controls, and diplomatic pressure on Russia for as long as it’s necessary.” (https://www.state.gov/secretary-antony-j-blinken-at-a-press-availability-18/).

  • Russia Features Prominently in Treasury Department’s 2022 Illicit Finance Strategy: On Friday, the Treasury Department released its 2022 National Strategy for Combatting Terrorist and Other Illicit Financing. As the first strategy published since the Russian invasion of Ukraine, the report mentions illicit finance activity involved in Russian sanctions evasion many times, and the Department promises to “(1) continue to identify and seize U.S. assets owned or controlled by designated Russians, including through the KleptoCapture and Russian Elites, Proxies, and Oligarchs (REPO) task forces; and (2) improve detection and reporting by financial institutions and other private sector entities of Russian sanctions evasion.” (https://home.treasury.gov/system/files/136/2022-National-Strategy-for-Combating-Terrorist-and-Other-Illicit-Financing.pdf).

UPDATE:

May 13, 2022

  • Deputy Treasury Secretary Urges International Banks to Stop Supporting Russia Sanctions Evasion: In private meetings on Friday, Deputy Treasury Secretary Wally Adeyemo met with representatives of international banks to lay out the consequences of helping Russians break sanctions. He focused on the “material support provision” that allows the US to take action if foreign domiciled banks help Russians evade sanctions. (https://www.nytimes.com/2022/05/13/us/politics/russia-sanctions-evasion-treasury.html).

  • Treasury Secretary Traveling to Europe: On Friday, the Treasury Department announced that Treasury Secretary Janet Yellen will travel to the G7 finance ministers meeting on May 19 and 20 in Germany. Prior to the meeting, she will travel to Warsaw, Poland and Brussels, Belgium. The travel announcement indicates that the Secretary and allies will “continue their united efforts to support Ukraine and to increase economic pressure on Russia to end its brutal and illegal war” during the trip. (https://home.treasury.gov/news/press-releases/jy0780).

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