Home > Sanctions/Export Highlights [As of October 27, 2022]
Sanctions/Export Highlights [As of October 27, 2022]
By Carlton Greene, Jeffrey L. Snyder, Anand Sithian & Kelsey Clinton on October 28, 2022
Posted in Bureau of Industry and Security (BIS), EU Sanctions, Export Controls, Iran Sanctions, Office of Foreign Assets Control (OFAC), Russia Sanctions
New U.S. Designations: On October 26, 2022, the U.S. Department of the Treasury’s Office of Foreign Asset Control (“OFAC”) designated nine individuals and twelve entities for their involvement in the Russian Federation’s corruption and influence campaign in Moldova. The designations included Igor Yuryevich Chayka, and Ivan Alesksandrovich Zavorotnyi, an associate of Chayka, for their actions related to election interference in Moldova. Both men own various Russian-located entities, which were also designated. In addition, OFAC designated Aleksei Valeryevich Troshin and the National Engineering Corporation (NIK) for their involvement in cybercrime.
EU Updates Guidance on Russian Sanctions: On October 24, 2022, the European Commission added five new FAQs to their guidance on business services prohibitions under the Russian Sanctions regime. The new FAQs lay out the scope of prohibited activities classified under IT consultancy services, architectural and engineering services, and legal advisory services. However, the Commission clarified that certain services “strictly necessary” for the termination of non-compliant contracts by January 8, 2023 are excluded from these prohibitions. The new guidance additionally included a table providing an overview of prohibited services and any relevant exemptions.
EU Leaders Discuss Additional Sanctions on Iran and Belarus: Brussels hosted a summit for European Union leaders on October 20 and 21, 2022, where the European Council demanded Russia “immediately, completely, and unconditionally” withdraw all of its military forces from Ukraine. The Council also called on Belarusian authorities to stop enabling Russian forces, noting that the EU remains ready to impose additional sanctions against Belarus if needed. During the summit, European leaders also discussed imposing wider sanctions on Iran for its involvement in supplying weapons to Russia and for the ongoing civil rights abuses in Iran.
BIS Under Secretary Suggests Additional Export Controls on the Way: At an event hosted by the Center for a New American Security, Under Secretary of Commerce for Industry and Security Alan Estevez discussed the recent BIS controls aimed at restricting exports of advanced technologies to both China and Russia. He noted that additional controls were likely to come “in the near term,” and would include a focus on emerging technologies, such as quantum information science, biotechnology, and artificial intelligence algorithms.
Carlton Greene is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade and White Collar & Regulatory Enforcement groups. He provides strategic advice to clients on U.S. economic sanctions, Bank Secrecy Act and anti-money laundering…
Carlton Greene is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade and White Collar & Regulatory Enforcement groups. He provides strategic advice to clients on U.S. economic sanctions, Bank Secrecy Act and anti-money laundering (AML) laws and regulations, export controls, and anti-corruption/anti-bribery laws and regulations. Carlton is the former chief counsel at FinCEN (the Financial Crimes Enforcement Network), the U.S. AML regulator responsible for administering the Bank Secrecy Act.
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Anand Sithian is a counsel in Crowell & Moring’s New York office. He is a member of the International Trade and the White Collar & Regulatory Enforcement groups. Anand advises clients on a variety of regulatory issues and investigations relating to anti-money laundering…
Anand Sithian is a counsel in Crowell & Moring’s New York office. He is a member of the International Trade and the White Collar & Regulatory Enforcement groups. Anand advises clients on a variety of regulatory issues and investigations relating to anti-money laundering (AML), the Bank Secrecy Act (BSA), U.S. economic sanctions, including those administered by the Office of Foreign Assets Control (OFAC), and asset forfeiture matters. Anand routinely counsels clients on the novel application of these laws and regulations to issues involving financial institutions, technology and social media, virtual currency and digital assets (including the seizure and forfeiture of virtual currencies), and the evolving cannabis industry.
Read more about Anand Sithian
Sanctions/Export Highlights [As of November 10, 2022]