MARCH 2022 EXPORT CONTROL REGULATION UPDATES
This newsletter is a listing of the latest changes in export control regulations through March 31, 2022. The newsletter is provided as a complimentary service to assist exporters with their ITAR and EAR export compliance responsibilities. It provides a summary of recent changes to export control regulations or other regulatory matters of interest that may impact your company’s international trade and export compliance functions. Call us at 703-847-5801 or email info@fdassociates.net with questions or comments.
See also our “Latest Sanctions Fines & Penalties” section below for an update on companies and persons denied export privileges by the United States Government.
REGULATORY UPDATES
Department of State
DDTC Issues Interim Final Rule To Amend The First Chapter Of The ITAR
March 23, 2022: 87 Fed. Reg. 16396: The U.S. Department of State has issued an interim final rule to amend the International Traffic in Arms Regulations (ITAR) Part 120 (first chapter) to better organize the purposes and definitions of the regulations. The rule consolidates and co-locates authorities, general guidance, and definitions. This rule restructures Part 120 of the ITAR to better organize the definitions previously found in that part and other parts of the ITAR and to consolidate provisions that provide background information or otherwise apply throughout the regulations. In addition, this rule adds text not previously found in the ITAR and makes clarifying revisions to existing text. None of the revisions change the current scope of the ITAR. This rule is intended to be the first in a series of rulemakings that will further streamline and clarify the regulations.
Prior to this rulemaking, generally applicable information and definitions were spread throughout the ITAR. As a result of this rulemaking, Part 120 is divided into three subparts:
- Subpart A - General Information;
- Subpart B - General Policies and Processes; and
- Subpart C - Definitions.
The division into subparts is intended to provide the reader with a roadmap for the regulations.
- Subpart A—General Information, consolidates and explains the legislative authority and purpose of the regulations to aid in understanding their importance and source.
- Subpart B—General Policies and Processes, outlines the general processes and policies of the ITAR.
- Subpart C—Definitions, provides a consolidated list of defined terms that are applicable throughout the ITAR.
DDTC is also revising those sections affected by this rule that use acronyms to follow a standard format. Where a single term for which there is a known acronym appears on more than two occasions within any one section, the first instance is followed by a parenthetical containing the acronym and subsequent use of the term is by acronym. This will provide consistency of format without sacrificing clarity and limits unnecessary text.
This interim final rule is effective September 6, 2022. If you would like to make a comment about this rule the Department of State is accepting comments through May 9, 2022.
See the Federal Register Notice for the complete changes to the ITAR as well as the Department of State’s website: https://www.federalregister.gov/documents/2022/03/23/2022-05629/international-traffic-in-arms-regulations-consolidation-and-restructuring-of-purposes-and and https://www.pmddtc.state.gov/ddtc_public?id=ddtc_public_portal_news_and_events
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Department of State Offers Millions In Rewards For Russian Cyber Criminals
March 24, 2022: The U.S. Department of State’s Rewards for Justice (RFJ) program is now offering a reward for information on Russian Federal Security Service (FSB) officers Pavel Aleksandrovich Akulov, Mikhail Mikhailovich Gavrilov, and Marat Valeryevich Tyukov for their alleged involvement in computer intrusions, wire fraud, aggravated identity theft, and damage to the property of an energy facility offenses. RFJ, which is administered by the Diplomatic Security Service, is offering a reward of up to $10 million for information leading to the identification or location of Akulov, Gavrilov, Tyukov, or any other person who, while acting at the direction or under the control of a foreign government, aids or abets a violation of the Computer Fraud and Abuse Act, which may include participation in malicious cyber activities against U.S. critical infrastructure. https://www.state.gov/rewards-for-justice-reward-offer-for-information-on-russian-fsb-officers-conducting-malicious-activity-against-u-s-critical-infrastructure-between-2012-2017/
The U.S. Department of State’s Rewards for Justice (RFJ) program is also offering a reward for information on Russia-based hacker Evgeny Viktorovich Gladkikh. RFJ is offering a reward of up to $10 million for information leading to the identification or location of Gladkikh or any other person who, while acting at the direction or under the control of a foreign government, aids or abets a violation of the Computer Fraud and Abuse Act, which may include participation in malicious cyber activities against U.S. critical infrastructure. https://www.state.gov/rewards-for-justice-reward-offer-for-information-on-russian-government-cyber-actor-for-conducting-malicious-activity-against-u-s-critical-infrastructure-in-2017-and-2018/
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Department of State, Directorate of Defense Trade Controls (DDTC)
March 2, 2022: 87 Fed. Reg. 11802: In accordance with the Paperwork Reduction Act of 1995, the U.S. Department of State's Directorate of Defense Trade Controls (DDTC) is seeking public comments on its Statement of Registration form (Form DS-2032). Interested persons have until May 2, 2022, to submit their comments. https://www.federalregister.gov/documents/2022/03/02/2022-04318/60-day-notice-of-proposed-information-collection-statement-of-registration
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DDTC Name And Address Changes Posted To Website
March 2 through 29, 2022: The Directorate of Defense Trade Controls (DDTC) posted the following name and/or address changes on its website at
- Change in address for CMI Defence America, Inc. from 7205 Sterling Ponds Court, Sterling Heights, Michigan, 48312 to 1920 Opdyke Court, Suite 100, Auburn Hills, Michigan, 48326;
- Change in name from L3 Westwood Corporation and SPD Electrical Systems, Inc. to L3Harris Maritime Power & Energy Solutions, Inc. due to corporate reorganization;
- Change in Name of the following L3Harris Technologies, Inc. Australia subsidiaries due to corporate rebranding:
| Previous Name | Amended Name |
| Exelis Australia Pty., Ltd. | L3Harris Exelis Australia Pty Ltd |
| Harris Communications (Australia) Pty Ltd | L3Harris Communications Australia Pty Ltd |
- Change in Name from Mikuni Corporation Aerospace & Machinery Company to Mikuni Aerospace Corporation due to corporate rebranding;
- Change in Name from QuantiTech LLC to Axient, LLC due to corporate rebranding;
- Change in Address for Claverham Limited from Rivermead Court 2, Kenn Business Park, Clevedon, Bristol BS21 6TH, UK to Fore 1, Fore Business Park, Huskisson Way, Stratford Road, Shirley, Solihull, England, B90 4SS, UK;
- Change in Name of the following L3Harris Technologies, Inc. UK subsidiaries due to corporate rebranding:
| Previous Name | Amended Name |
| L-3 Communications ASA Limited | L3Harris Technologies ASA Limited |
| EDO MBM Technology Limited | L3Harris Release & Integrated Solutions Inc. |
| TRL Technology Ltd. | L3Harris TRL Technology Ltd. |
- Change in Name of the following L3Harris Technologies, Inc. UK subsidiaries due to corporate rebranding:
| Previous Name | Amended Name |
| L3 Commercial Training Solutions Ltd. | L3Harris Commercial Training Solutions Limited |
| L3Harris Systems UK Limited | L3Harris Communications Systems UK Limited |
- Change in Address for MTG Marinetechnik GmbH from Wandsbeker Koenigstrasse 62, 22041 Hamburg, Germany to MTG Marinetechnik GmbH at Budnikowsky-Twiete 7, 22041 Hamburg, Germany;
- Changes in Name from Yokogawa Electric Corporation and Yokogawa Manufacturing Corporation to Oki Electric Industry Co., Ltd., due to acquisition;
- Change in Name from Altran Switzerland AG to Capgemini Suisse SA due to acquisition;
- Change in Name from Air Nostrum Lineas Aereas del Mediterraneo SAU to Air Nostrum Engineering and Maintenance Operations SLU due to corporate rebranding.
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Department of Commerce – Bureau of Industry and Security (BIS)
Commerce Takes Additional Actions Related To Exports Of Certain Materials And Adds Parties To The Entity List
March 3, 2022: 87 Fed. Reg. 12856 and 87 Fed. Reg. 13141: The U.S. Department of Commerce's Bureau of Industry and Security (BIS) has taken two additional actions in response to Russia's invasion of Ukraine, both effective March 3:
- The first action/final rule builds on existing restrictions BIS put in place on the Russian deepwater oil and gas exploration and extraction industries in 2014 by imposing a policy of denial on such items and applying similarly stringent restrictions on a wide variety of items necessary for refining oil. This rule expands the scope of the sanctions against the Russian industry sector that was originally added to the EAR in August 2014 in response to Russia's 2014 destabilizing conduct in Ukraine and occupation of the Crimea region of Ukraine. See 79 FR 45675 (Aug. 6, 2014). The export controls in this final rule target the oil refinery sector in Russia. This final rule amends part 746 of the EAR (Embargoes and Other Special Controls) to expand the scope of the Russian industry sector sanctions by adding a new general prohibition that will apply to additional Harmonized Tariff Schedule (HTS)-6 codes and Schedule B numbers for all exports, reexports, and transfers (in-country) to or within Russia. Refer to Supplement No. 2 to 22 CFR § 746. file (doc.gov)
- The second final rule implemented adds 91 new parties in 10 countries to the Commerce Department’s Entity List. The parties were added to the list upon a determination by the interagency End-User Review Committee (ERC), made up of the Departments of Commerce (Chair), Defense, State, Energy, and where appropriate, Treasury, based upon their involvement in, contributions to, or other support of the Russian security services, military and defense sectors, and military and/or defense research and development efforts. These entities are located in: Russia (81), United Kingdom (3), Estonia (3), Spain (2), Malta (2), Kazakhstan (1), Latvia (1), Belize (1), Singapore (1), and Slovakia (1) (NOTE: Total entries is 96 as some entities operate in multiple countries). The entities added to the Entity List via the final rule are as follows:
Belize
- Ecotherm-Cryo Limited.
Estonia
- ADIMIR OU;
- Eastline Technologies OU; and
- Valery Kosmachov.
Kazakhstan
- Serniya Engineering.
Latvia
- Ecotherm-Cryo Limited.
Malta
- Djeco Group LP; and
- Malberg Limited.
Russia
- Amur Shipbuilding Factory PJSC;
- AO Center of Shipbuilding and Ship Repairing JSC;
- AO Kronshtadt;
- Avant Space LLC;
- Baikal Electronics;
- Center for Technological Competencies in Radiophtonics;
- Central Research and Development Institute Tsiklon;
- Crocus Nano Electronics;
- Dalzavod Ship-Repair Center;
- Elara;
- Electronic Computing and Information Systems;
- ELPROM;
- Engineering Center Ltd.;
- Forss Technology Ltd.;
- Integral SPB;
- JSC Element;
- JSC Pella-Mash;
- JSC Shipyard Vympel;
- Kranark LLC;
- Lev Anatolyevich Yershov (Ershov);
- LLC Center;
- MCST Lebedev;
- Miass Machine-Building Factory;
- Microelectronic Research and Development Center Novosibirsk;
- MPI VOLNA;
- N.A. Dollezhal Order of Lenin Research and Design Institute of Power Engineering;
- Nerpa Shipyard;
- NM-Tekh;
- Novorossiysk Shipyard JSC;
- NPO Electronic Systems;
- NPP Istok;
- NTC Metrotek;
- OAO GosNIIkhimanalit;
- OAO Svetlovskoye Predpriyatiye Era;
- OJSC TSRY;
- OOO Elkomtekh (Elkomtex);
- OOO Planar;
- OOO Sertal;
- Photon Pro LLC;
- PJSC Zvezda;
- Production Association Strela;
- Radioavtomatika;
- Research Center Module;
- Robin Trade Limited;
- R.Ye. Alekseyev Central Design Bureau for Hydrofoil Ships;
- Rubin Sever Design Bureau;
- Russian Space Systems;
- Rybinsk Shipyard Engineering;
- Scientific Research Institute of Applied Chemistry;
- Scientific-Research Institute of Electronics;
- Scientific Research Institute of Hypersonic Systems;
- Scientific Research Institute NII Submikron;
- Sergey IONOV;
- Serniya Engineering;
- Severnaya Verf Shipbuilding Factory;
- Ship Maintenance Center Zvezdochka;
- State Governmental Scientific Testing Area of Aircraft Systems (GkNIPAS);
- State Machine Building Design Bureau Raduga Bereznya;
- State Scientific Center AO GNTs RF—FEI A.I. Leypunskiy Physico-Energy Institute;
- State Scientific Research Institute of Machine Building Bakhirev (GosNIImash);
- Tomsk Microwave and Photonic Integrated Circuits and Modules Collective Design Center;
- UAB Pella-Fjord;
- United Shipbuilding Corporation JSC “35th Shipyard”;
- United Shipbuilding Corporation JSC “Astrakhan Shipyard”;
- United Shipbuilding Corporation JSC “Aysberg Central Design Bureau”;
- United Shipbuilding Corporation JSC “Baltic Shipbuilding Factory”;
- United Shipbuilding Corporation JSC “Krasnoye Sormovo Plant OJSC”;
- United Shipbuilding Corporation JSC “SC “Zvyozdochka”;
- United Shipbuilding Corporation “Pribaltic Shipbuilding Factory Yantar”;
- United Shipbuilding Corporation “Scientific Research Design Technological Bureau Onega”;
- United Shipbuilding Corporation “Sredne-Nevsky Shipyard”;
- Ural Scientific Research Institute for Composite Materials;
- Urals Project Design Bureau Detal;
- Vega Pilot Plant;
- Vertikal LLC;
- Vladislav Vladimirovich Fedorenko;
- VTK Ltd;
- Yaroslavl Shipbuilding Factory;
- ZAO Elmiks-VS;
- ZAO Sparta; and
- ZAO Svyaz Inzhiniring.
Singapore
- Alexsong PTE LTD.
Slovakia
- Incoff Aerospace S.R.O.
Spain
- Invention Bridge SL; and
- Majory LLP.
United Kingdom
- Djeco Group LP.
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Commerce modifies The Sanctions Against Russia and Belarus and Adds Countries Excluded From the FDP Rule
March 10, 2022: The U.S. Department of Commerce's Bureau of Industry and Security (BIS) in response to the Russian Federation’s (Russia’s) further invasion of Ukraine, and to protect U.S. national security and foreign policy interests, the Department of Commerce has added new and highly restrictive license requirements and policies for certain transactions involving Russia and Belarus under the Export Administration Regulations (EAR). Refer to § 746.8. In order to recognize partner countries that have committed to implementing substantially similar new export controls on Russia and Belarus in their domestic laws, the Department of Commerce has published a list of countries (supplement No. 3 to §746) excluded from portions of these new U.S. export controls (§ 746.8(a)(5)).
These exclusions apply specifically to certain requirements under the EAR related to foreign-produced items. In this rule, the Department of Commerce adds the Republic of Korea (South Korea) to the list of excluded countries. (See our February 2022 issue for details on the original actions taken against Russia and Belarus)
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Commerce Consolidates Russian Guidance On Its Webpage
The U.S. Department of Commerce's Bureau of Industry and Security (BIS) has created a webpage related to all of the changes that have taken place due to Russia’s invasion of Ukraine. https://www.bis.doc.gov/index.php/policy-guidance/country-guidance/russia-belarus
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The U.S. Department of Commerce, National Institute of Standards and Technology
The U.S. Department of Commerce, National Institute of Standards and Technology issued guidance entitled, “Assessing Enhanced Security Requirements for Controlled Unclassified Information.” The purpose of this publication is to describe procedures for assessing the enhanced security requirements in [SP 800-172]. Compliance with the security requirements is addressed in CUI guidance and the CUI Federal Acquisition Regulation (FAR) or as supplemented by federal agencies (e.g., Department of Defense Federal Acquisition Regulation). Organizations can use the assessment procedures to generate evidence to support the assertion that the enhanced security requirements have been satisfied. The assessment procedures are typically used as part of an assessment process. An assessment process is an information-gathering and evidence producing activity to determine the effectiveness of the safeguards implemented to meet the set of security requirements specified in [SP 800-172]
https://nvlpubs.nist.gov/nistpubs/SpecialPublications/NIST.SP.800-172A.pdf
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U.S. Census Bureau
Census Updates HTS Codes Not Schedule B#S For 2022
March 1, 2022: Effective March 1, 2022, all recent updates and corrections to the Harmonized Tariff Schedule (HTS) are available for use in AES.
Note: There are no changes to Schedule B.
AES accepted shipments with outdated codes during a grace period of 30 days beyond the expiration date of February 28, 2022. Reporting an outdated code after the 30-day grace period will result in a fatal error.
The ACE AESDirect program is updated with the new HTS codes and accepted shipments with outdated codes during the grace period.
The full 2022 Schedule B and HTS tables are available for download at:
http://www.census.gov/foreign-trade/aes/documentlibrary/#concordance
The current list of HTS codes that are not valid for AES are available at:
https://www.census.gov/foreign-trade/aes/documentlibrary/concordance/hts-not-for-aes.txt
| LATEST SANCTIONS FINES & PENALTIES |
This section of our newsletter provides information on the latest sanctions, fines, and penalties for export violations or matters of non-compliance with the ITAR or EAR issued by the US government enforcement agencies. It is provided as a service to exporters and associates of FD Associates to remind them of the importance of extreme due diligence in all international trade and export compliance matters, particularly those involving exports subject to the ITAR or the EAR. Don't let this happen to you or your company! Call us with questions or concerns at 703-847-5801 or email info@fdassociates.net.
Sanctions
The President
March 3, 2022: 87 Fed. Reg. 12553: The President continued the National Emergency with respect to Zimbabwe. The actions and policies of certain members of the Government of Zimbabwe and other persons to undermine Zimbabwe's democratic processes or institutions continue to pose an unusual and extraordinary threat to the foreign policy of the United States. For this reason, the national emergency declared on March 6, 2003, and the measures adopted on that date, on November 22, 2005, and on July 25, 2008, to deal with that emergency, must continue in effect beyond March 6, 2022. Therefore, in accordance with section 202(d) of the National Emergencies Act (50 U.S.C. 1622(d)), I am continuing for 1 year the national emergency declared in Executive Order 13288.
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March 8, 2022: The President signed Executive Order 14066 banning the import of Russian oil, liquefied natural gas, and coal to the United States – a significant action with widespread bipartisan support that further deprives President Putin of the economic resources he uses to continue his needless war of choice -- the U.S. Treasury released one General License and several Frequently Asked Questions to aid in the wind-down of deliveries of existing purchases that have already been contracted for. The United States continues to take severe action to hold the Russian Federation accountable for its brutal, unprovoked invasion of Ukraine. Treasury has targeted the infrastructure supporting President Putin’s invasion of Ukraine, from his cronies to state-owned companies and even the Central Bank, restricting over 80% of the total banking assets in Russia. These actions, in coordination with partners and allies, have isolated Russia from the global financial system and degraded the Kremlin’s ability to project power. https://home.treasury.gov/system/files/126/eo_14066.pdf
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March 11, 2022: The President Signed Executive Order 14068 prohibiting the following:
- The importation into the United States of the following products of Russian Federation origin: fish, seafood, and preparations thereof; alcoholic beverages; non-industrial diamonds; and any other products of Russian Federation origin as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State and the Secretary of Commerce;
- The exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of luxury goods, and any other items as may be determined by the Secretary of Commerce, in consultation with the Secretary of State and the Secretary of the Treasury, to any person located in the Russian Federation;
- New investment in any sector of the Russian Federation economy as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State, by a United States person, wherever located;
- The exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of U.S. dollar-denominated banknotes to the Government of the Russian Federation or any person located in the Russian Federation; and
- Any approval, financing, facilitation, or guarantee by a United States person, wherever located, of a transaction by a foreign person where the transaction by that foreign person would be prohibited by this section if performed by a United States person or within the United States.
https://home.treasury.gov/system/files/126/14068.pdf
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The U.S. Department of State:
March 15, 2022: the Department of State has imposed sanctions on the following Russian military leaders.
Specifically, the following 11 individuals are designated pursuant to E.O. 14024 Section 1(a)(i), as persons who operate or have operated in the defense and related materiel sector of the Russian Federation economy:
- ALEKSEY KRIVORUCHKO is a Russian Ministry of Defense Deputy Minister of Defense;
- TIMUR IVANOV is a Russian Ministry of Defense Deputy Minister of Defense;
- YUNUS-BEK EVKUROV is a Russian Ministry of Defense Deputy Minister of Defense;
- DMITRY BULGAKOV is a Russian Deputy Minister of Defense and a General of the Army; Bulgakov is the Russian Federation Ministry of Defense’s senior-most officer responsible for logistics matters;
- YURIY SADOVENKO is a Russian Ministry of Defense Deputy Minister of Defense;
- NIKOLAY PANKOV is a Russian Ministry of Defense Deputy Minister of Defense;
- RUSLAN TSALIKOV is a Russian Ministry of Defense Deputy Minister of Defense;
- GENNADY ZHIDKO is a Russian Ministry of Defense Deputy Minister of Defense;
- VIKTOR ZOLOTOV is a Russian General of the Army and Commander-in-Chief of Russia’s National Guard Troops. He is a member of Russia’s Security Council;
- DMITRY SHUGAEV is a senior leader of the Russian Ministry of Defense who is the Director of the Russian Ministry of Defense’s Federal Service for Military Technical Cooperation; and
- ALEXANDER MIKHEEV is the Director-General of Rosoboronexport, which is Russia’s state-controlled intermediary that carries out foreign trade with respect to military goods. Mikheev has been involved in synchronizing the supplies of weapons and special equipment using the Russian Ministry of Defense’s capabilities; has served as a member of an organizing committee led by Russia’s Minister of Defense of a Russian Ministry of Defense-organized military-focused forum; and has served on a delegation led by Russia’s Minister of Defense.
https://www.state.gov/u-s-announces-sanctions-on-key-members-of-russias-defense-enterprise/
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March 24, 2022: 87 Fed. Reg. 16819: On March 14, 2022, the U.S. Department of State applied the measures authorized in Section 3 of the Iran, North Korea, and Syria Nonproliferation Act (Pub. L. 109-353) against the following foreign persons identified in the report submitted pursuant to Section 2(a) of the Act:
- Zhengzhou Nanbei Instrument Equipment Co. Ltd (People's Republic of China) and any successor, sub-unit, or subsidiary thereof;
- Second Academy of Natural Science Foreign Affairs Bureau (SANS FAB) (DPRK) and any successor, sub-unit, or subsidiary thereof;
- Ri Sung Chol (aka Ri Su'ng-ch'o'l) (DPRK individual);
- Ardis Group of Companies LLC (Russia) and any successor, sub-unit, or subsidiary thereof;
- PFK Profpodshipnik, LLC (Russia) and any successor, sub-unit, or subsidiary thereof;
- Igor Aleksandrovich Michurin (Russian individual).
Accordingly, pursuant to Section 3 of the Act, the following measures are imposed on these persons:
- No department or agency of the U.S. government may procure or enter into any contract for the procurement of any goods, technology, or services from these foreign persons, except to the extent that the Secretary of State otherwise may determine;
- No department or agency of the U.S. government may provide any assistance to these foreign persons, and these persons shall not be eligible to participate in any assistance program of the U.S. government, except to the extent that the Secretary of State otherwise may determine;
- No U.S. government sales to these foreign persons of any item on the United States Munitions List are permitted, and all sales to these persons of any defense articles, defense services, or design and construction services under the Arms Export Control Act are terminated; and
- No new individual licenses shall be granted for the transfer to these foreign persons of items the export of which is controlled under the Export Control Reform Act of 2018 or the Export Administration Regulations, and any existing such licenses are suspended.
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Department of Commerce, Bureau of Industry and Security (BIS)
March 8, 2022: 87 Fed. Reg. 13048: The Department of Commerce, Bureau of Industry and Security (BIS) added new license requirements and review policies for Belarus to the Export Administration Regulations (EAR) to render Belarus subject to the same sanctions that were imposed on Russia under the EAR effective February 24, 2022. These new sanctions impose new Commerce Control List (CCL)-based license requirements for Belarus; revise the two foreign “direct product” rules (FDP rules) that are specific to Russia and Russian `military end users' to make them also applicable to Belarus and Belarusian `military end-users;' specify a license review policy of denial applicable to all of the license requirements on Belarus that are being added in this rule, with certain limited exceptions; significantly restrict the use of EAR license exceptions; expand the existing `military end use' and `military end user' control scope to include Belarus for all items “subject to the EAR” other than food and medicine designated EAR99, and add two new Belarusian entities to the Entity List as `military end-users.' This rule also imposes a license requirement for nuclear nonproliferation items for exports and reexports to Belarus and removes Belarus from Country Group A:4 under the EAR. In addition, for Belarus and Russia, this rule amends the availability of License Exceptions AVS and ENC and includes clarifying guidance on the availability of CCD. https://www.federalregister.gov/documents/2022/03/08/2022-04819/imposition-of-sanctions-against-belarus-under-the-export-administration-regulations-ear
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March 11, 2022: 87 Fed. Reg. 14785: The U.S. Commerce Department’s Bureau of Industry and Security (BIS) imposed restrictions on the export, reexport, and transfer (in-country) of luxury goods to all end-users in the Russian Federation (Russia) and Belarus and to certain Russian and Belarusian oligarchs and malign actors located worldwide. For purposes of these new license requirements, a `luxury good' refers to any item that is identified in new supplement no. 5 to part 746 of the EAR. The license requirement specific to Russia and Belarus for `luxury goods' is added under new § 746.10(a)(1) of the EAR (`Luxury goods' license requirements for Russia and Belarus) (Embargoes and Other Special Controls). The license requirement specific to the designated Russian and Belarusian oligarchs and malign actors for `luxury goods' is added under new § 746.10(a)(2) of the EAR (Worldwide license requirement for `luxury goods' for designated Russian and Belarusian oligarch and malign actors). https://www.federalregister.gov/documents/2022/03/16/2022-05604/imposition-of-sanctions-on-luxury-goods-destined-for-russia-and-belarus-and-for-russian-and
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March 18, 2022: the U.S. Commerce Department, through its Bureau of Industry and Security (BIS), publicly identified commercial and private aircraft that have flown into Russia in apparent violation of the EAR. In so doing, BIS is notifying the public that providing any form of service to these aircraft requires authorization. Absent such authorization, any person anywhere—including within Russia—risks violating the EAR and would be subject to BIS enforcement actions which could include substantial jail time, fines, loss of export privileges, or other restrictions. By preventing these aircraft from receiving any service, for example from abroad, international flights from Russia on these aircraft are effectively grounded. https://www.commerce.gov/news/press-releases/2022/03/commerce-department-identifies-commercial-and-private-aircraft-exported
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Department of the Treasury, Office of Foreign Assets Control (OFAC)
March 1, 2022: 87 Fed. Reg. 11297: On April 15, 2021, President Biden, invoking the authority of, inter alia, the International Emergency Economic Powers Act (50 U.S.C. 1701 et seq. ) (IEEPA), issued Executive Order (E.O.) 14024, “Blocking Property With Respect To Specified Harmful Foreign Activities of the Government of the Russian Federation” (86 FR 20249, April 19, 2021).
In E.O. 14024, the President found that specified harmful foreign activities of the Government of the Russian Federation—in particular, efforts to undermine the conduct of free and fair democratic elections and democratic institutions in the United States and its allies and partners; to engage in and facilitate malicious cyber-enabled activities against the United States and its allies and partners; to foster and use transnational corruption to influence foreign governments; to pursue extraterritorial activities targeting dissidents or journalists; to undermine security in countries and regions important to United States national security; and to violate well-established principles of international law, including respect for the territorial integrity of states—constitute an unusual and extraordinary threat to the national security, foreign policy, and economy of the United States and declared a national emergency to deal with that threat.
OFAC is issuing the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (the “Regulations”), to implement E.O. 14024, pursuant to authorities delegated to the Secretary of the Treasury in E.O. 14024. A copy of E.O. 14024 appears in appendix A to this part.
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March 1, 2022: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated four Islamic State of Iraq and Syria (ISIS) and ISIS-Mozambique (ISIS-M) financial facilitators based in South Africa. ISIS members and associates in South Africa are playing an increasingly central role in facilitating the transfer of funds from the top of the ISIS hierarchy to branches across Africa. The South Africa-based ISIS members designated today pursuant to Executive Order (E.O.) 13224, as amended, have provided support for the aforementioned transfers or served as leaders of ISIS cells in South Africa. The following individuals have been added to OFAC’s SDN List:
- ABADIGGA, Abdella Hussein of South Africa;
- HOOMER, Farhad of South Africa;
- MBAGA, Peter Charles of South Africa; and
- MILLER, Siraaj of South Africa.
https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220301 and
https://home.treasury.gov/news/press-releases/jy0616
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March 2, 2022: The Department of the Treasury's Office of Foreign Assets Control (OFAC) issued Russia-related General License 9A, General License 10A, General License 13, and General License 14. In addition, OFAC has published new Frequently Asked Questions and updated several Frequently Asked Questions. OFAC issued this new public guidance to cut off avenues for potential sanctions evasion by the Central Bank of the Russian Federation. This guidance makes clear that there should be no loopholes for Russia to evade the unprecedented prohibitions by the United States to lock up Russia’s war chest – Central Bank of the Russian Federation, National Wealth Fund of the Russian Federation, and Ministry of Finance of the Russian Federation – that were imposed the week of March 2, 2022.
Russia has taken steps to use exporters to act as their agents and help them raise resources to prop up their currency and fund their priorities. OFAC’s guidance makes clear that such actions on behalf of Russia’s Central Bank are prohibited, closing off attempts to access the U.S. financial system. OFAC issued frequently asked questions (FAQs) for enhanced compliance with U.S. sanctions and further explains recent sanctions actions, including the prohibitions imposed pursuant to Directive 4 under Executive Order (E.O.) 14024, “Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the
Russian Federation” (Russia-related Sovereign Transactions Directive). https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220302 and https://home.treasury.gov/news/press-releases/jy0624
General License 9A: All transactions prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587, that are ordinarily incident and necessary to dealings in debt or equity of one or more of the following entities issued prior to February 24, 2022 (“covered debt or equity”) are authorized through 12:01 a.m. eastern daylight time, May 25, 2022, provided that any divestment or transfer of, or facilitation of divestment or transfer of, covered debt or equity must be to a non-U.S. person: (1) State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank; (2) Public Joint Stock Company Bank Financial Corporation Otkritie; (3) Sovcombank Open Joint Stock Company; (4) Public Joint Stock Company Sberbank of Russia; (5) VTB Bank Public Joint Stock Company; or (6) Any entity in which one or more of the above entities own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest. https://home.treasury.gov/system/files/126/russia_gl9a.pdf
General License 10A: All transactions prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587, that are ordinarily incident and necessary to the wind down of derivative contracts entered into prior to 4:00 p.m. eastern standard time, February 24, 2022, that (i) include one of the following entities (together, the “Covered Entities”) as a counterparty or (ii) are linked to debt or equity of a Covered Entity are authorized through 12:01 a.m. eastern daylight time, May 25, 2022, provided that any payments to a blocked person are made into a blocked account: (i) State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank; (ii) Public Joint Stock Company Bank Financial Corporation Otkritie; (iii) Sovcombank Open Joint Stock Company; (iv) Public Joint Stock Company Sberbank of Russia; (v) VTB Bank Public Joint Stock Company; or (vi) Any entity in which one or more of the above entities own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest. https://home.treasury.gov/system/files/126/russia_gl10a.pdf
General License 13: U.S. persons are authorized to pay taxes, fees, or import duties, and purchase or receive permits, licenses, registrations, or certifications, to the extent such transactions are prohibited by Directive 4 under Executive Order (E.O.) 14024, Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation, provided such transactions are ordinarily incident and necessary to such persons’ day-to-day operations in the Russian Federation, through 12:01 a.m. eastern daylight time, June 24, 2022. https://home.treasury.gov/system/files/126/russia_gl13.pdf
General License 14: All transactions prohibited by Directive 4 under Executive Order (E.O). 14024, Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation, involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation (collectively, “Directive 4 entities”), where the Directive 4 entity’s sole function in the transaction is to act as an operator of a clearing and settlement system, are authorized, provided that: (i) there is no transfer of assets to or from any Directive 4 entity, unless separately authorized; and (ii) no Directive 4 entity is either a counterparty or a beneficiary to the transaction unless separately authorized. https://home.treasury.gov/system/files/126/russia_gl14.pdf
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March 3, 2022: The Department of the Treasury's Office of Foreign Assets Control (OFAC) issued Russia-related General License 15 which, authorizes all transactions prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR), involving any entity owned 50 percent or more, directly or indirectly, by Alisher Burhanovich Usmanov that is not listed on OFAC’s Specially Designated Nationals and Blocked Persons List (“blocked Usmanov entity”). All property and interests in property of the blocked Usmanov entities are unblocked, and debits to accounts on the books of a U.S. financial institution of the blocked Usmanov entities are authorized. This general license does not authorize any transactions otherwise prohibited by the RuHSR or involving any person blocked or otherwise sanctioned pursuant to the RuHSR, including Alisher Burhanovich Usmanov, or his property or interests in property, other than the blocked Usmanov entities unless separately authorized. https://home.treasury.gov/system/files/126/russia_gl15.pdf
In addition, the following names have been added to OFAC's Specially Designated Nationals List (SDN List):
- ARESHEV, Andrey Grigoryevich of Russia;
- BESPALOV, Anton Sergeyevich of Russia;
- BUBNOVA, Irina Sergeyevna of Russia;
- CHEMEZOV, Alexander Sergeevich of Russia;
- CHEMEZOV, Stanislav Sergeyevich of Russia;
- CHUGULEVA, Aleyona Anatolyevna of Russia;
- DOROKHOVA, Nina Viktorovna of Russia;
- DUGINA, Darya Aleksandrovna of Russia;
- FEDIN, Yuriy Sergeyevich of the Ukraine and Russia;
- GAFNER, Denis Yakovlevich of Russia;
- GLOTOV, Yevgeniy Eduardovich of the Ukraine;
- IGNATOVA, Anastasia of Russia;
- IGNATOVA, Yekaterina Sergeyevna of Russia;
- ILYASHENKO, Andrey Vitalyevich of Russia;
- KALABAYEVA, Valeriya of Russia;
- KAMYSHANOVA, Aleksandra Aleksandrovna of Russia;
- KIRILLOVA, Anastasiya Sergeyevna of Russia;
- KNYRIK, Konstantin Sergeyevich of Crimea, Ukraine and Russia;
- KRANS, Maksim Iosifovich of Russia;
- KRASOVSKIY, Maksim Borisovich of Russia;
- MAKSIMENKO, Vladimir Ilich of Russia;
- MAMAKOVA, Aelita Leonidovna of Russia;
- NEZHDANOVA, Yevgeniya Vitalyevna of Russia;
- PESKOV, Dmitriy Sergeevich of Russia;
- POGREBENKOV, Valeriy Ivanovich of Russia;
- PRIGOZHIN, Pavel Evgenyevich of Russia;
- PRIGOZHINA, Lyubov Valentinovna of Russia;
- PRIGOZHINA, Polina Evgenyevna of Russia;
- PROKOFYEV, Yuriy Anatolyevich of Russia;
- ROTENBERG, Boris Borisovich of Russia and Finland;
- ROTENBERG, Karina Yurevna of Russia and France;
- ROTENBERG, Liliya Arkadievna of Russia;
- ROTENBERG, Pavel Arkadyevich of Russia;
- SAENKO, Sergei Ivanovich of Russia;
- SHUVALOV, Evgeny Igorevich of Russia;
- SHUVALOV, Igor Ivanovich of Russia;
- SHUVALOVA, Maria Igorevna of Russia;
- SHUVALOVA, Olga Viktorovna of Russia;
- SINELIN, Mikhail Anatolyevich of Russia;
- SKOROKHODOVA, Natalya Petrovna of Russia;
- TATARCHENKO, Denis Sergeyevich of Russia;
- TOKAREV, Nikolay Petrovich of Russia and Kazakhstan;
- TOKAREVA, Galina Alekseyevna of Russia;
- TOKAREVA, Maiya Nikolaevna of Russia and Kazakhstan;
- USMANOV, Alisher Burhanovich of Russia, Monaco and Uzbekistan; and
- ZAMLELOVA, Svetlana Georgiyevna of Russia.
The following entities have been added to OFAC's SDN List:
- ALTITUDE X3 LTD of Bermuda;
- AVANFORT OOO of Russia;
- AVIASTAR-SP AIRCRAFT MANUFACTURING ENTERPRISE of Russia;
- DESIGN BUREAU OF SPECIAL MACHINE-BUILDING of Russia;
- FIRMA VEARDON OOO of Russia;
- GEOPOLITICA of Russia;
- IRKUTSK AVIATION PLANT of Russia;
- IZHEVSK UNMANNED SYSTEMS RESEARCH AND PRODUCTION ASSOCIATED LIMITED LIABILITY COMPANY of Russia;
- JOINT STOCK COMPANY AVANGARD of Russia;
- JOINT STOCK COMPANY FEDERAL SCIENTIFIC AND PRODUCTION CENTER TITAN BARRIKADY of Russia;
- JOINT STOCK COMPANY ODK-KLIMOV of Russia;
- JOINT STOCK COMPANY RESEARCH AND PRODUCTION CORPORATION of Russia;
- JOINT STOCK COMPANY SALAVAT CHEMICAL PLANT of Russia;
- JOURNAL KAMERTON of Russia;
- JSC CENTRAL RESEARCH INSTITUTE OF AUTOMATION AND HYDRAULICS of Russia;
- JSC NOVOSIBIRSK AIRCRAFT PRODUCTION ASSOCIATION PLANT NAMED AFTER V.P. CHKALOV of Russia;
- JSC RESEARCH AND PRODUCTION ASSOCIATION KVANT of Russia;
- KATINA DRUSTVO S OGRANICENOM ODGOVORNOSCU ZA NEKRETNINE I UGOSTITELJSTVO of Croatia;
- KOMSOMOLSK-ON-AMUR AVIATION PLANT of Russia;
- KURGANMASHZAVOD of Russia;
- LAKHTA PARK PREMIUM, OOO of Russia;
- LAKHTA PARK, OOO of Russia;
- LAKHTA PLAZA, OOO of Russia;
- LIMITED LIABILITY COMPANY NEMCHINOVO INVESTMENTS of Russia;
- LIMITED LIABILITY COMPANY OSTOZHENKA 19 of Russia;
- MAKEYEV STATE MISSILE CENTER of Russia;
- NEW EASTERN OUTLOOK of Russia;
- NIZHNIY NOVGOROD SOKOL AIRCRAFT MANUFACTURING PLANT of Russia;
- ODK-SATURN PUBLIC JOINT-STOCK COMPANY of Russia;
- ODNA RODYNA of Russia;
- ORIENTAL REVIEW of Russia;
- OTKRYTYE AKTIVY OOO of Russia;
- PUBLIC JOINT-STOCK COMPANY ODK-KUZNETSOV of Russia;
- PUBLIC JOINT-STOCK COMPANY ODK-UFIMSKOYE MOTOROSTROITELNOYE PRODUCTION ASSOCIATION of Russia;
- RADIOAVTOMATIKA LLC of Russia;
- RHYTHM OF EURASIA of Russia;
- SOVA NEDVIZHIMOST OOO of Russia;
- G.A. D.O.O. ZA TRGOVINU I USLUGE of Russia;
- THE PLANAR COMPANY of Russia;
- UNITED WORLD INTERNATIONAL of Russia;
- VSEROSSISKIY INSTITUT AVIATSIONNYKH MATERIALOV of Russia; and
- ZARECHE-4 OOO of Russia.
The following vessel has been added to OFAC's SDN List:
- DILBAR (ZGFO) Yacht 15,917GRT Cayman Islands flag.
The following aircraft have been added to OFAC's SDN List:
- LX-MOW; Aircraft Model GVI G650; and
- M-IABU Aircraft Model Airbus A340-300; Aircraft Manufacturer's Serial Number (MSN) 955; Aircraft Tail Number M-IABU.
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March 4, 2022: The Department of the Treasury's Office of Foreign Assets Control (OFAC) issued the following three new Frequently Asked Questions regarding Russian sanctions:
- Do I have to wind down energy-related transactions by the expiration date of the Russia-related General License (GL) 8A?
- My U.S. bank refused to process a requested payment related to energy despite the authorization in Russia-related General License (GL) 8A under Executive Order (E.O.) 14024. What can I do?
- My company transports Russian oil for sale to the United States and third countries. Can I continue to transport or sell Russian-origin oil without violating sanctions pursuant to Executive Order (E.O.) 14024?
For answers to these FAQs see the following link: https://home.treasury.gov/policy-issues/financial-sanctions/faqs/added/2022-03-04
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March 4, 2022: The Department of the Treasury's Office of Foreign Assets Control (OFAC) designated two key Hizballah financiers operating in Guinea pursuant to Executive Order (E.O.) 13224, as amended. This action is aimed at disrupting Hizballah’s business network in West Africa, which relies on bribery and influence to circumvent the rule of law. In addition to other sources of funding, Hizballah generates revenue from commercial activities across the world to sponsor acts of terrorism. The designation of these financiers demonstrates the Treasury’s ongoing efforts to target the terrorist group’s international commercial activities and its global network of financiers, supporters, donors, and facilitators, which enable Hizballah to persistently threaten the security, stability, and prosperity of Lebanon and other jurisdictions. The Hizballah financiers added to the SDN list are:
- SAADE, Ali of Guinea, Lebanon, and France;
- TAHER, Ibrahim of Guinea, Lebanon, and the United Kingdom.
https://home.treasury.gov/news/press-releases/jy0631 and https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220304
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March 7, 2022: The Department of the Treasury's Office of Foreign Assets Control (OFAC) added the following entity to the SDN list:
- KATIBAT AL TAWHID WAL JIHAD (a.k.a. JANNAT OSHIKLARI; a.k.a. KHATIBA AL-TAWHID WAL-JIHAD; a.k.a. TAWHID AND JIHAD BRIGADE; a.k.a. "KTJ") of Syria; Kyrgyzstan; Russia.
https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220307
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March 8, 2022: As a result of Executive Order 14066, the Department of the Treasury's Office of Foreign Assets Control (OFAC) issued Russia-related General License 16. In addition, OFAC has published new Frequently Asked Questions and updated several Frequently Asked Questions.
Russia-related General License 16: Except as provided in paragraph (b) of this general license, all transactions prohibited by Executive Order (E.O.) of March 8, 2022, Prohibiting Certain Imports and New Investments With Respect to Continued Russian Federation Efforts to Undermine the Sovereignty and Territorial Integrity of Ukraine, that are ordinarily incident and necessary to the importation into the United States of crude oil; petroleum; petroleum fuels, oils, and products of their distillation; liquefied natural gas; coal; and coal products of Russian Federation origin pursuant to written contracts or written agreements entered prior to March 8, 2022 are authorized through 12:01 a.m. eastern daylight time, April 22, 2022. (b) This general license does not authorize any transactions otherwise prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR), including involving any person blocked pursuant to the RuHSR, unless separately authorized.
OFAC added the following Frequently Asked Questions:
· What does Executive Order (E.O.) of March 8, 2022, “Prohibiting Certain Imports and New Investments With Respect to Continued Russian Federation Efforts to Undermine the Sovereignty and Territorial Integrity of Ukraine,” do?
OFAC also updated the following two Frequently Asked Questions:
· My company transports Russian oil for sale to the United States and third countries. Can I continue to transport or sell Russian-origin oil without violating sanctions pursuant to Executive Order (E.O.) 14024?
· Can a U.S. financial institution process transactions related to energy where a Russian financial institution sanctioned pursuant to Executive Order (E.O.) 14024 is involved?
Answers to the FAQs can be found at the links below.
https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220308 and https://home.treasury.gov/system/files/126/russia_gl16.pdf and https://home.treasury.gov/policy-issues/financial-sanctions/faqs/added/2022-03-08 and https://home.treasury.gov/policy-issues/financial-sanctions/faqs/976
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March 11, 2022: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned two individuals and three entities for supporting North Korea’s defense industry ongoing development of its weapons of mass destruction (WMD) and ballistic missile programs in violation of multiple United Nations Security Council resolutions (UNSCRs). North Korea’s defense industry has conducted 11 ballistic missile launches since the beginning of the year, most recently on March 4, 2022 (EST). This action targets a group of foreign individuals and companies that aid a North Korean defense industry-related procurement agent in Russia; much of this activity also violates UN prohibitions with respect to North Korea. The two individuals are:
- Andreyevich Gayevoy (Gayevoy) of Russia; and
- Pak Kwang Hun of North Korea.
The three entities are:
- Apollon OOO of Russia;
- Zeel – M Co., Ltd of Russia; and
- RK Briz, OOO of Russia.
The following individuals have been added to OFAC's SDN List:
- AFONIN, Yuriy Vyacheslavovich of Russia;
- ANDRESOV, Yuriy Nikolaevich of Russia;
- BELOUS, German Valentinovich of Russia;
- BESSONOV, Yevgeniy Ivanovich of Russia;
- CHASOVNIKOV, Aleksandr Aleksandrovich, of Russia;
- DERGUNOVA, Olga Konstantinovna of Russia;
- DIRKS, Natalia Germanova of Russia;
- GAYEVOY, Aleksandr Andreyevich of Russia;
- GEORGIEVA, Elena Aleksandrovna of Russia;
- KALASHNIKOV, Leonid Ivanovich of Russia;
- KASHIN, Vladimir Ivanovich of Russia;
- KNYAGININ, Vladimir Nikolaevich of Russia;
- KOLOMEITSEV, Nikolay Vasilievich of Russia;
- KONDRATENKO, Maxim Dmitrievich, of Russia;
- KOVALCHUK, Boris Yurievich of Russia;
- KOVALCHUK, Kira Valentinovna of Russia;
- KOVALCHUK, Stepan Kirillovich of Russia;
- KOVALCHUK, Tatyana Aleksandrovna of Russia;
- KULIK, Vadim Valerievich of Russia;
- KURINNIY, Aleksey Vladimirovich of Russia;
- LUKYANENKO, Valerii Vasilyevich of Russia;
- MELNIKOV, Ivan Ivanovich of Russia;
- NAVKA, Tatiana Aleksandrovna of Russia;
- NOROV, Erkin Rakhmatovich of Russia;
- NOVIKOV, Dmitriy Georgievich of Russia;
- OSADCHIY, Nikolay Ivanovich of Russia;
- OSTROVSKY, Svyatoslav Evgenievich of Russia;
- PECHATNIKOV, Anatolii Yuryevich of Russia;
- PESKOV, Nikolay of Russia;
- PESKOVA, Elizaveta Dmitriyevna of Russia;
- PYANOV, Dmitrii Vasilyevich of Russia;
- SAPELIN, Andrey Yurievich of Russia;
- TAYSAEV, Kazbek Kutsukovich of Russia;
- VAVULIN, Dmitri Nikolaevich of Russia; and
- ZYUGANOV, Gennady Andreyevich of Russia.
The following entities have been added to OFAC's SDN List:
- APOLLON OOO of Russia;
- RK BRIZ, OOO of Russia; and
- ZEEL - M CO., LTD. of Russia.
The following vessel has been added to OFAC's SDN List:
- TANGO (E5U3540) Yacht 2,083GRT Cook Islands flag; Vessel Registration Identification IMO 1010703; MMSI 518100626 (vessel).
The following aircraft have been added to OFAC's SDN List:
- P4-MIS; Aircraft Manufacture Date 31 May 2007; Aircraft Model Airbus A319-115.
https://home.treasury.gov/news/press-releases/jy0651 and https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220311
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March 11, 2022: The Department of the Treasury's Office of Foreign Assets Control (OFAC) issued Russia-related General License 17, General License 18, and General License 19 and Ukraine-related General License 23. OFAC has also published new Frequently Asked Questions and amended one Frequently Asked Question.
General License 17: All transactions prohibited by section 1(a)(i) of Executive Order of March 11, 2022, Prohibiting Certain Imports, Exports, and New Investment With Respect to Continued Russian Federation Aggression, that are ordinarily incident and necessary to the importation into the United States of fish, seafood, and preparations thereof; alcoholic beverages; or non-industrial diamonds of Russian Federation origin pursuant to written contracts or written agreements entered into prior to March 11, 2022, were authorized through 12:01 a.m. eastern daylight time, March 25, 2022. The general license does not authorize any transactions otherwise prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR), including involving any person blocked pursuant to the RuHSR, unless separately authorized. https://home.treasury.gov/system/files/126/russia_gl17.pdf
General License 18: All transactions prohibited by section (1)(a)(iv) of Executive Order of March 11, 2022, Prohibiting Certain Imports, Exports, and New Investment With Respect to Continued Russian Federation Aggression, that are ordinarily incident and necessary to the transfer of U.S. dollar-denominated banknote noncommercial, personal remittances from: (i) the United States or a U.S. person, wherever located, to an individual located in the Russian Federation; or (ii) a U.S. person who is an individual located in the Russian Federation, are authorized.
Note to paragraph (a)(1). Noncommercial, personal remittances do not include charitable donations to or for the benefit of an entity or funds transfers for use in supporting or operating a business, including a family-owned business. (2) Transferring institutions may rely on the originator of a funds transfer with regard to compliance with paragraph (a)(1) of this general license, provided that the transferring institution does not know or have reason to know that the funds transfer is not in compliance with paragraph (a)(1). (b) This general license does not authorize any transactions otherwise prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR), or involving any person blocked pursuant to RuHSR, unless separately authorized. https://home.treasury.gov/system/files/126/russia_gl18.pdf
General License 19: Individuals who are U.S. persons located in the Russian Federation are authorized to engage in all transactions prohibited by section 1(a)(iv) of Executive Order of March 11, 2022, Prohibiting Certain Imports, Exports, and New Investment With Respect to Continued Russian Federation Aggression, that are ordinarily incident and necessary to their personal maintenance within the Russian Federation, including payment of housing expenses, acquisition of goods or services for personal use, payment of taxes or fees, and purchase or receipt of permits, licenses, or public utility services. This general license does not authorize any transactions otherwise prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR), including involving any person blocked pursuant to the RuHSR, unless separately authorized. https://home.treasury.gov/system/files/126/russia_gl19.pdf
Ukraine-related General License 23: All transactions prohibited by Executive Order (E.O.) 14065 that are ordinarily incident and necessary to the activities described in paragraph (b) by nongovernmental organizations are authorized, including the processing and transfer of funds, payment of taxes, fees, and import duties, and purchase or receipt of permits, licenses, or public utility services. This general license does not authorize any transactions involving any person blocked pursuant to E.O. 14065, unless otherwise authorized. https://home.treasury.gov/system/files/126/ukraine_gl23.pdf
New Frequently Asked Questions:
· Does the U.S. dollar-denominated banknote export ban imposed by Executive Order (E.O.) of March 11, 2022, “Prohibiting Certain Imports, Exports, and New Investment With Respect to Continued Russian Federation Aggression,” prohibit sending noncommercial, personal remittances denominated in U.S. dollars to the Russia Federation (or to individuals ordinarily resident in the Russia Federation)?
· For the purposes of Executive Order (E.O.) of March 11, 2022, “Prohibiting Certain Imports, Exports, and New Investment With Respect to Continued Russian Federation Aggression,” what is meant by the terms “Russian Federation origin,” “fish, seafood, and preparations thereof,” “alcoholic beverages,” and “non-industrial diamonds”?
· Are non-U.S. persons exposed to sanctions if they continue to import to non-U.S. jurisdictions certain products of Russian Federation origin that are banned from the United States pursuant to Executive Order (E.O.) of March 11, 2022, “Prohibiting Certain Imports, Exports, and New Investment With Respect to Continued Russian Federation Aggression”?
· Executive Order (E.O.) of March 11, 2022, “Prohibiting Certain Imports, Exports, and New Investment With Respect to Continued Russian Federation Aggression” prohibits the importation into the United States of fish, seafood, and preparations thereof of Russian Federation origin. How does this affect Russia-related General License (GL) 6?
· I have a shipment of a certain product(s) listed in Executive Order (E.O.) 14068 en route to the United States that were contracted prior to March 11, 2022. Can I find a new buyer for this shipment, re-direct the shipment to a country other than the United States, or import the product(s) and comply with the import ban?
· Is there a period of time for U.S. persons to continue importing products prohibited by Executive Order (E.O.) 14068?
· What does Executive Order (E.O.) of March 11, 2022, “Prohibiting Certain Imports, Exports, and New Investment With Respect to Continued Russian Federation Aggression,” do?
· Do the prohibitions of Executive Order (E.O.) 14024 and other Russia-related sanctions extend to virtual currency?
For answers to these Frequently Asked Questions, see the following link: https://home.treasury.gov/policy-issues/financial-sanctions/faqs/added/2022-03-11
The following Frequently Asked Question was amended:
- Are U.S. persons authorized to engage in certain activity with the so-called Donetsk People’s Republic and Luhansk People’s Republic regions of Ukraine or such other regions of Ukraine as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State (collectively, the “Covered Regions")?
For the answer to this Frequently Asked Questions, see the following link: https://home.treasury.gov/policy-issues/financial-sanctions/faqs/updated/2022-03-11
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March 15, 2022: The Department of the Treasury's Office of Foreign Assets Control (OFAC) added the following individuals to the OFAC SDN List:
- AKHMATOV, Dzhabrail Alkhazurovich of Russia;
- BULGAKOV, Dmitry of Russia;
- EVKUROV, Yunus-Bek of Russia;
- IVANOV, Timur of Russia;
- KHUTAEV, Khusein Merlovich of Russia;
- KRIVORUCHKO, Aleksey of Russia;
- LUKASHENKA, Halina Radzivonawna of Belarus;
- MIKHEEV, Aleksander Aleksandrovich of Russia;
- MUSHNIKOVA, Natalia Evgenievna of Russia;
- PANKOV, Nikolay of Russia;
- SADOVENKO, Yuriy of Russia;
- SALAMOV, Nurid Denilbekovich of Russia;
- SHUGAYEV, Dmitry of Russia;
- TSALIKOV, Ruslan, of Russia; and
- ZHIDKO, Gennady of Russia and Uzbekistan.
The following entity has been added to OFAC's SDN List:
- Kurchaloi District Of The Chechen Republic Branch Of The Ministry Of Internal Affairs Of The Russian Federation.
https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220315
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March 15, 2022: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated four individuals and one entity pursuant to the Sergei Magnitsky Rule of Law Accountability Act of 2012 (the Russia Magnitsky Act). These Russia Magnitsky Act targets were involved in concealing events surrounding the death of renowned Russian whistleblower Sergei Magnitsky, or were connected to gross violations of human rights against Russian human rights defender Oyub Titiev. Treasury is also re-designating Alyaksandr Lukashenka of Belarus, the head of a corrupt government in Belarus whose patronage network benefits his inner circle and regime, and newly designating his wife pursuant to Executive Order (E.O.) 13405.
- The four individuals that were sanctioned on March 15th are:
- Alyaksandr Lukashenka of Belarus;
- Halina Radzivonawna Lukashenka of Belarus;
- Natalia Mushnikova or Russia;
- Dzhabrail Alkhazurovich Akhmatov of Chechnya.
The entity sanctioned on March 15th is:
- Kurchaloi District of the Chechen Republic Branch of the Ministry of Internal Affairs of the Russian Federation of Chechnya.
https://home.treasury.gov/news/press-releases/jy0654 and https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220315
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March 17, 2022: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), sanctioned Alain Goetz, the African Gold Refinery in Uganda, and a network of companies involved in the illicit movement of gold valued at hundreds of millions of dollars per year from the Democratic Republic of the Congo.
The following individual has been added to OFAC's SDN List:
- GOETZ, Alain Francois Viviane of the United Arab Emirates, Belgium and Turkey
The following entities have been added to OFAC's SDN List:
- AFRICAN GOLD REFINERY LIMITED of Uganda;
- AGOR DMCC of the United Arab Emirates;
- AGR INTERNATIONAL LIMITED of the Seychelles;
- ALAXY of Belgium;
- CG - VASTGOED INVEST of Belgium;
- GOETZ GOLD LLC of the United Arab Emirates;
- OROFINO NV of Belgium;
- PREMIER GOLD REFINERY LLC of the United Arab Emirates; and
- WWG DIAMONDS of Belgium.
https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220317 and https://home.treasury.gov/news/press-releases/jy0664
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March 18, 2022: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Ukraine-/Russia-related General License 24. Under the General License all transactions prohibited by Executive Order (E.O.) 14065 related to the provision or receipt of civil maritime services performed by individuals who are ordinarily resident in the so-called Donetsk People’s Republic (DNR) or Luhansk People’s Republic (LNR) regions of Ukraine, or such other regions of Ukraine as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State (collectively, the “Covered Regions”), are authorized, provided that:
(1) Such services are performed outside the Covered Regions; and
(2) Such services are not performed on behalf of any entity located in, or organized under the laws of, the Covered Regions.
This general license does not authorize:
(1) Any new investment in the Covered Regions prohibited by E.O. 14065 unless separately authorized; or
(2) Any transactions involving any person blocked pursuant to E.O. 14065 unless separately authorized.
https://home.treasury.gov/system/files/126/ukraine_gl24.pdf
OFAC also issued the following additional Frequently Asked Question:
- Does Executive Order (E.O.) 14066 prohibit dealing in Kazakh-origin crude oil of the Caspian Pipeline Consortium (“CPC”)?
The answer to this Frequently Asked Question can be found at: https://home.treasury.gov/policy-issues/financial-sanctions/faqs/updated/2022-03-18
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March 18, 2022: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated the Los Huistas Drug Trafficking Organization (DTO) and its leaders pursuant to Executive Order (E.O.) 14059 for drug trafficking that threatens the people and security of the United States and Guatemala. The Los Huistas DTO is the dominant criminal structure in the Guatemalan department of Huehuetenango (along the border of Guatemala and Mexico).
The following individuals have been added to OFAC's SDN List:
- MOLINA LOPEZ of Guatemala;
- MOLINA MONTEJO of Guatemala;
- MONTEJO SAENZ of Guatemala;
- MORENO LOPEZ of Guatemala;
- SALAZAR FLORES of Guatemala;
- SAMAYOA MONTEJO of Guatemala; and
- SAMAYOA RECINOS of Guatemala.
The following entities have been added to OFAC's SDN List:
- COMPRADORES Y EXPORTADORES DE CAFE CAPTZIN, SOCIEDAD ANONIMA of Guatemala; LOS HUISTAS DRUG TRAFFICKING ORGANIZATION of Guatemala.
The following deletion has been made to OFAC's SDN List:
- ROSENTHAL HIDALGO, of Honduras.
March 21, 2022: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) added the following entity to OFAC’s SDN List:
- CENTRAL RESERVE POLICE of Sudan.
https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220321 and
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March 24, 2022: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Russia-related General License 6A, General License 17A, General License 20, and Ukraine-/Russia-related General License 25. In addition, OFAC has updated two Frequently Asked Questions.
General License 6A: All transactions prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR), that are ordinarily incident and necessary to: (1) the exportation or reexportation of agricultural commodities, medicine, medical devices, replacement parts and components for medical devices, or software updates for medical devices to, from, or transiting the Russian Federation; (2) the prevention, diagnosis, or treatment of COVID-19 (including research or clinical studies relating to COVID-19); or (3) ongoing clinical trials and other medical research activities that were in effect prior to March 24, 2022, are authorized. https://home.treasury.gov/system/files/126/russia_gl6a.pdf
General License 17A: All transactions prohibited by section 1(a)(i) of Executive Order (E.O.) 14068 that are ordinarily incident and necessary to the importation into the United States of alcoholic beverages or non-industrial diamonds of Russian Federation origin pursuant to written contracts or written agreements entered into prior to March 11, 2022, are authorized through 12:01 a.m. eastern daylight time, March 25, 2022. All transactions prohibited by section 1(a)(i) of E.O. 14068 that are ordinarily incident and necessary to the importation into the United States of fish, seafood, and preparations thereof of Russian Federation origin pursuant to written contracts or written agreements entered into prior to March 11, 2022 are authorized through 12:01 a.m. eastern daylight time, June 23, 2022. This general license does not authorize any transactions otherwise prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR), including involving any person blocked pursuant to the RuHSR, unless separately authorized. Effective March 24, 2022, General License No. 17, dated March 11, 2022, is replaced and superseded in its entirety by this General License No. 17A. https://home.treasury.gov/system/files/126/russia_gl17a.pdf
General License 20: U.S. persons are authorized to engage in all transactions ordinarily incident and necessary to the official business of third-country diplomatic or consular missions located in the Russian Federation that are prohibited by Executive Order (E.O.) 14024 or section 1(a)(iv) of E.O. 14068. https://home.treasury.gov/system/files/126/russia_gl20.pdf
Ukraine Russia Related General License 25: News reporting organizations that are United States persons, and individuals who are United States persons regularly employed by a news reporting organization, either as journalists (including photojournalists) or as supporting broadcast or technical personnel, are authorized to engage in the following transactions in the Crimea region of Ukraine, the so-called Donetsk People’s Republic (DNR) or Luhansk People’s Republic (LNR) regions of Ukraine, or such other regions of Ukraine as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State (collectively, the “Covered Regions”), to the extent such transactions are ordinarily incident and necessary to their journalistic activities in the Covered Regions. https://home.treasury.gov/system/files/126/ukraine_gl25.pdf
Updated Frequently Asked Questions:
I have a shipment of a certain product(s) listed in Executive Order (E.O.) 14068 en route to the United States that was contracted prior to March 11, 2022. Can I find a new buyer for this shipment, re-direct the shipment to a country other than the United States, or import the product(s) and comply with the import ban?
Is there a period of time for U.S. persons to continue importing products prohibited by Executive Order (E.O.) 14068?
Answers to these updated Frequently Asked Questions can be found at: https://home.treasury.gov/policy-issues/financial-sanctions/faqs/updated/2022-03-24
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March 24, 2022: In its latest action to impose severe costs on the Russian Federation for its illegal, unwarranted, and baseless war against Ukraine, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated key enablers of the invasion. This includes dozens of Russian defense companies, 328 members of the Russian State Duma, and the head of Russia’s largest financial institution. See the following link for the extensive list of individuals added to OFAC’s SDN List: https://home.treasury.gov/news/press-releases/jy0677
The following entities have been added to OFAC's SDN List:
- AKTSIONERNOE OBSHCHESTVO ELEKTROTYAGA of Russia;
- AKTSIONERNOE OBSHCHESTVO GOSUDARSTVENNOE NAUCHNO PROIZVODSTVENNOE PREDPRIYATIE REGION of Russia;
- AKTSIONERNOE OBSHCHESTVO PETROVSKII ELEKTROMEKHANICHESKII ZAVOD MOLOT of Russia;
- AKTSIONERNOE OBSHCHESTVO RAVENSTVO-SERVICE of Russia;
- AKTSIONERNOE OBSHCHESTVO SARATOVSKI RADIOPRIBORNYI ZAVOD of Russia;
- AKTSIONERNOE OBSHCHESTVO TURAEVSKOE MASHINOSTROITELNOE KONSTRUKTORSKOE BYURO SOYUZ of Russia;
- AKTSIONERNOE OBSHCHESTVO VERKHNEUFALEISKII ZAVOD URALELEMENT of Russia;
- INTERNATIONAL HELICOPTERS PROGRAMS LIMITED LIABILITY COMPANY of Russia;
- JOINT STOCK COMPANY 150 AIRCRAFT REPAIR PLANT of Russia;
- JOINT STOCK COMPANY 356 AIRCRAFT REPAIR PLANT of Russia;
- JOINT STOCK COMPANY 711 AIRCRAFT REPAIR PLANT of Russia;
- JOINT STOCK COMPANY 810 AIRCRAFT REPAIR PLANT of Russia;
- JOINT STOCK COMPANY AZOVSKI OPTIKO MECHANICHESKY ZAVOD of Russia;
- JOINT STOCK COMPANY CENTRAL DESIGN BUREAU OF AUTOMATICS of Russia;
- JOINT STOCK COMPANY CONCERN GRANIT-ELECTRON of Russia;
- JOINT STOCK COMPANY CONCERN SEA UNDERWATER WEAPON GIDROPRIBOR of Russia;
- JOINT STOCK COMPANY DAGDIZEL PLANT of Russia;
- JOINT STOCK COMPANY HELICOPTER SERVICE COMPANY of Russia;
- JOINT STOCK COMPANY KAZAN HELICOPTERS of Russia;
- JOINT STOCK COMPANY KRONSHTADT of Russia;
- JOINT STOCK COMPANY KUMERTAU AVIATION PRODUCTION ENTERPRISE of Russia;
- JOINT STOCK COMPANY MACHINE BUILDING DESIGN BUREAU of Russia;
- JOINT STOCK COMPANY NATIONAL HELICOPTER CENTER MIL AND KAMOV of Russia;
- JOINT STOCK COMPANY PROGRESS ARSENYEV AVIATION COMPANY of Russia;
- JOINT STOCK COMPANY REDUCTOR of Russia;
JOINT STOCK COMPANY RESEARCH AND DESIGN INSTITUTE SEA THERMAL ENGINEERING of Russia; - JOINT STOCK COMPANY RYAZANSKOE KONSTRUKTORSKOE BJURO GLOBUS of Russia;
- JOINT STOCK COMPANY SALUTE of Russia;
- JOINT STOCK COMPANY SEVERNIY PRESS of Russia;
- JOINT STOCK COMPANY SMOLENSK AIRCRAFT PLANT of Russia;
- JOINT STOCK COMPANY STATE MACHINE BUILDING DESIGN BUREAU VYMPEL BY NAME I.I. TOROPOV of Russia;
- JOINT STOCK COMPANY STUPINO ENGINEERING PRODUCTIVE ENTERPRISE of Russia;
- JOINT STOCK COMPANY ULAN-UDE AVIATION PLANT of Russia;
- JOINT STOCK COMPANY URAL DESIGN BUREAU DETAL of Russia;
- JOINT STOCK COMPANY ZAVOD KULAKOVA of Russia;
- JSC MBDB ISKRA of Russia;
- JSC NPO HIGH PRECISION SYSTEMS of Russia;
- JSC RAWENSTVO of Russia;
- LIMITED LIABILITY COMPANY CENTER OF PURCHASES AND LOGISTICS OF THE HELICOPTER INDUSTRY of Russia;
- NPK TEKHMASH OAO of Russia;
- OBSHCHESTVO S OGRANICHENNOI OTVETSVENNOSTYU VR-RESURS of Russia;
- PUBLIC JOINT STOCK COMPANY ARZAMASSKOE NAUCHNO PROIZVODSTVENNOE PREDPRIYATIE TEMP-AVIA of Russia;
- RADUGA STATE MACHINE BUILDING DESIGN BUREAU JOINT STOCK COMPANY of Russia;
- ROSTOV HELICOPTER PRODUCTION COMPLEX of Russia;
- STATE DUMA OF THE FEDERAL ASSEMBLY OF THE RUSSIAN FEDERATION of Russia;
- STATE SCIENTIFIC RESEARCH INSTITUTE OF MECHANICAL ENGINEERING IMENI V.V. BAKHIREVA of Russia;
- TACTICAL MISSILES CORPORATION JSC of Russia;
- TRV AUTO LIMITED LIABILITY COMPANY of Russia;
- VERTOLETY ROSSII AO of Russia.
The following vessel has been added to OFAC's SDN List:
- LENA (ZJL8309) Yacht British Virgin Islands flag; Vessel Registration Identification IMO 9594339.
https://home.treasury.gov/news/press-releases/jy0677
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March 25, 2022: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated five individuals and five entities connected to Burma’s military regime pursuant to Executive Order (E.O) 14014. OFAC also designated six individuals connected to the Nigeria-based terrorist group, Boko Haram. All six were found guilty of establishing a Boko Haram cell in the United Arab Emirates (UAE) to raise funds for and provide material assistance to Boko Haram insurgents in Nigeria.
The following individuals have been added to OFAC's SDN List:
- ADAMU, Salihu Yusuf of Nigeria and the United Arab Emirates;
- ALHASSAN, Ibrahim Ali of Nigeria;
- AUNG, Naing Htut of Burma;
- AUNG, Sit Taing of Burma;
- HEIN, Zaw of Burma;
- ISA, Muhammed Ibrahim of Nigeria and the United Arab Emirates;
- MUHAMMAD, Surajo Abubakar of Nigeria and the United Arab Emirates;
MUSA, Abdurrahman Ado of Nigeria and the United Arab Emirates; - OO, Aung Hlaing of Burma;
- OO, Ko Ko, Zayyarthiri, Nay Pyi Taw of Burma; and
- YUSUF, Bashir Ali of Nigeria.
The following entities have been added to OFAC's SDN List:
- 66TH LIGHT INFANTRY DIVISION of Burma;
- ASIA GREEN DEVELOPMENT BANK LTD of Burma;
- HTOO GROUP OF COMPANIES of Burma;
- INTERNATIONAL GATEWAYS GROUP OF COMPANY LIMITED of Burma; and
MYANMAR CHEMICAL AND MACHINERY COMPANY LIMITED of Burma.
https://home.treasury.gov/news/press-releases/jy0679 and https://home.treasury.gov/news/press-releases/jy0678 and https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220325
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March 30, 2022: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned an Iran-based procurement agent and his network of companies that procured ballistic missile propellant-related materials for the Islamic Revolutionary Guard Corps Research and Self Sufficiency Jihad Organization (IRGC RSSJO), the IRGC unit responsible for the research and development of ballistic missiles, as well as Iran’s Parchin Chemical Industries (PCI), an element of Iran’s Defense Industries Organization (DIO). OFAC is also taking action against a key Iranian intermediary involved in the procurement of parts used to develop missile propellant on behalf of PCI.
The following individual has been added to OFAC's SDN List:
- HOSSEINI, Mohammad Ali of Iran.
The following entities have been added to OFAC’s SDN List:
- JESTAR SANAT DELIJAN of Iran;
B. SADR CO. of Iran; - SAYEHBAN SEPEHR DELIJAN of Iran; and
- SINA COMPOSITE DELIJAN COMPANY of Iran.
https://home.treasury.gov/news/press-releases/jy0689 and https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220330
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March 31, 2022: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) is continuing to impose severe costs on the Russian Federation for its unprovoked and unjustified war against Ukraine by targeting operators in the Russian technology sector to prevent it from evading unprecedented multilateral sanctions and procure critical western technology. OFAC designated 21 entities and 13 individuals as part of its crackdown on the Kremlin’s sanctions evasion networks and technology companies, which are instrumental to the Russian Federation’s war machine. Treasury has also determined that three new sectors of the Russian Federation economy are subject to sanctions pursuant to Executive Order 14024 (E.O. 14024).
The following individuals have been added to OFAC's SDN List:
- BERNOVA, Evgeniya Vladimirovna of Germany and Russia;
- BOBKOV, Sergei Alekseevich of Russia;
- DUBROVINSKIY, Viacheslav Yuryevich of Russia;
- GLADKIKH, Evgeny Viktorovich of Russia;
- GRININ, Yevgeniy Aleksandrovich of Russia;
- KRUGOVOV, Anton Alekseevich of Russia;
- MALEVANYY, Konstantin Vasilyevich of Russia;
- NIKOLAEVA, Irina Viktorovna of Russia;
- PODGORNOVA, Yevgeniya Aleksandrovna of Russia;
- SOBOLEV, Nikita Aleksandrovich of Russia;
- TOPCHI, Tamara Aleksandrovna of Russia;
- YERSHOV, Sergey Aleksandrovich of Russia; and
- ZAKHAROV, Andrey Georgiyevich of Russia.
The following entities have been added to OFAC's SDN List:
- ALEXSONG PTE LTD of Singapore;
- AO NII VEKTOR of Russia;
- DJECO GROUP HOLDING LTD of Malta;
- DJECO GROUP LP of the United Kingdom;
- INVENTION BRIDGE SL of Spain;
- JOINT STOCK COMPANY MIKRON of Russia;
- MAJORY LLP of the United Kingdom;
- MALBERG LIMITED, of Malta;
- MALTARENT LTD of Malta;
- MOLECULAR ELECTRONICS RESEARCH INSTITUTE, JOINT STOCK COMPANY of Russia;
- OOO FOTON PRO of Russia;
- OOO NAUCHNO-TEKHNICHESKII TSENTR METROTEK of Russia;
- OOO PAMKIN KHAUS of Russia;
- OOO ROBIN TREID of Russia;
- OOO SERNIYA INZHINIRING of Russia;
- OOO SERTAL of Russia;
- PHOTON PRO LLP of the United Kingdom;
- QUANTLOG OY of Finland;
- SCI GRIBER of France;
- SERNIA-FILM CO, LTD of Russia; and
- T-PLATFORMS of Russia.
The following deletions have been made to OFAC's SDN List:
- LIMITED LIABILITY COMPANY OZON BANK of Russia; and
- LLC OZON BANK of Russia.
https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220331 and https://home.treasury.gov/news/press-releases/jy0692
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U.S. Departments of Justice and Treasury
March 16, 2022: Attorney General Merrick B. Garland and Secretary of the Treasury Janet L. Yellen met virtually with representatives from Australia, Canada, Germany, France, Italy, Japan, the United Kingdom, and the European Commission, to launch the Russian Elites, Proxies, and Oligarchs (REPO) multilateral task force. The task force was first announced by leaders on Feb. 26. The task force, consisting of Finance Ministry and Justice or Home Ministry in each member jurisdiction, each committed to using their respective authorities in concert with other appropriate ministries to collect and share information to take concrete actions, including sanctions, asset freezing, civil and criminal asset seizure, and criminal prosecution.
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Fines and Penalties
March 1, 2022: Thomas Harris Jr., 29, of Croydon, PA, was sentenced to three years and 10 months in prison, and three years of supervised release for multiple firearms trafficking offenses stemming from his scheme to sell almost 40 guns to a buyer on the island of St. Lucia. https://www.justice.gov/usao-edpa/pr/bucks-county-man-sentenced-nearly-four-years-trafficking-firearms-st-lucia
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March 4, 2022: Joe Sery, former owner and chief executive officer of Tungsten Heavy Powder & Parts, and his brother, Dror Sery, were charged in a federal grand jury indictment with violations of federal export laws pursuant to the International Traffic in Arms Regulations (ITAR). Tungsten Heavy Powder & Parts, or THPP, is a San Diego-based company that provides tungsten fragments, sub-assemblies, and other weapon grade components for United States military contracts. According to the indictment, between January 1, 2016, and December 12, 2019, Joe Sery entered into contracts with various aerospace and defense companies on behalf of THPP. Joe Sery then obtained ITAR- controlled technical data and drawings from these companies to allow THPP to fulfill the contracted order. Some of THPP’s projects included the construction of an Advanced Rapid Response Weapon, a 155-millimeter Bi-Modal Warhead, a R9E Warhead, and an 81-millimeter Cowling Cone. These drawings contained information, which is required for the design, development, production, manufacture, assembly, operation, repair, testing, maintenance, or modification of defense articles. Despite being educated and trained regarding the requirements of ITAR, Joe Sery and his brother Dror Sery – a foreign national and dual citizen of Israel and South Africa – knowingly and willfully exported from the United States to the People’s Republic of China, the Republic of India and elsewhere overseas, defense articles covered by the United States Munitions List without first obtaining permission from the United States Department of State’s Directorate of Defense Trade Controls. Joe Sery is expected to be arraigned in federal court on Monday; an arrest warrant has been issued for fugitive Dror Sery. He is believed to be residing in Israel. https://www.justice.gov/usao-sdca/pr/former-tungsten-heavy-powder-parts-ceo-arrested-and-charged-unlawful-exportation
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March 8, 2022: Two former senior Venezuelan prosecutors have been charged with money laundering for their receipt of bribes in exchange for agreeing not to pursue criminal charges against certain individuals in Venezuela. According to the indictment, Daniel D’Andrea Golindano (D’Andrea), 43, and Luis Javier Sanchez Rangel (Sanchez), 35, both of Venezuela, are each charged with one count of conspiracy to commit money laundering and two counts of engaging in monetary transactions in the criminally derived property.
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March 29, 2022: The former Comptroller General of Ecuador made his initial appearance in a Miami, Florida courtroom, for allegedly engaging in a scheme to use the U.S. financial system to launder money to promote and conceal an illegal bribery scheme in Ecuador. According to the March 24 indictment, between approximately 2010 and 2016, Carlos Ramon Polit Faggioni (Polit), allegedly solicited and received over $10 million in bribe payments from Odebrecht S.A., the Brazil-based construction conglomerate, in exchange for using his official position as Comptroller General of Ecuador to influence official actions by the comptroller’s office in order to benefit Odebrecht and its business in Ecuador. Additionally, Polit is alleged to have received a bribe from an Ecuadorian businessman in or around 2015 in exchange for assisting the businessman and his company in connection with certain contracts from the state-owned insurance company of Ecuador. https://www.justice.gov/opa/pr/former-comptroller-general-ecuador-indicted-alleged-bribery-and-money-laundering-scheme
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