OFAC, BIS and State mark Ukraine independence day with sanctions
US government departments marked Ukraine’s Independence Day (24 August) by imposing a slew of measures the day before it fell.
The US Office of Foreign Assets Control (‘OFAC’) said that new designations built on previous sanctions, and that ‘the U.S. Department of the Treasury and the Department of State [had] targeted nearly 400 individuals and entities both in Russia and outside its borders—including in Asia, Europe, and the Middle East—whose products and services enable Russia to sustain its war effort and evade sanctions.’
OFAC said it was’ targeting numerous transnational networks, including those involved in procuring ammunition and military materiel for Russia, facilitating sanctions evasion for Russian oligarchs through offshore trust and corporate formation services, evading sanctions imposed on Russia’s cyber actors, laundering gold for a sanctioned Russian gold company, and supporting Russia’s military-industrial base by procuring sensitive and critical items such as advanced machine tools and electronic components.’
It also said that the measures were intended to ‘further limit Russia’s future revenue from metals and mining [and targeting] Russian financial technology companies that provide necessary software and IT solutions for Russia’s financial sector.’
Accompanying the designations, OFAC has issued several general licences relating to imports of diamonds and diamond jewellery, authorizing ‘limited safety and environmental transactions and the unloading of cargo involving certain blocked persons or vessels,’ and others.
The US Bureau of Industry and Security (‘US BIS’) has also taken measures, including: ‘
- Further tightening controls on Russia by expanding the scope of the Russia/Belarus Military End User (MEU) and Procurement Foreign Direct Product (FDP) rule and imposing additional license requirements on operation software for computer numerically controlled (CNC) machine tools;
- Cutting off exports to foreign companies on the BIS Entity List; applying the expanded Russia/Belarus MEU and Procurement FDP rule to dozens of entities outside Russia;
- Restricting trade to additional foreign addresses and issuing guidance to exporters on identifying suspicious transactions related to foreign corporate service providers and listed foreign addresses, strengthening recently implemented restrictions on shell company addresses; and
- Providing guidance and recommendations on contractual language referencing export regulations (the Export Administration Regulations, or EAR), specifically, restrictions that target unlawful reexports to Russia and Belarus.’
