U.S. regulations regarding Russia, Belarus and Ukraine sanctions and controls are rapidly evolving. This summary is not meant to be comprehensive, and some information may be superseded by subsequent changes/updates to U.S. rules.
It is strongly advised that University offices, faculty, staff or students who have engaged in or anticipate engaging in transactions with, exports or imports to/from, or agreements with individuals or entities located in Russia, Belarus, Ukraine or any other Covered Region consult with their local Export Control office to determine if their activities are affected by sanctions or license requirements.
Agency: | Date: | Link to Notice: |
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Treasury | Publication 2/23/22 | 87 FR 10293 |
Summary of Change: |
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The President signed a new Executive Order – Blocking Property Of Certain Persons And Prohibiting Certain Transactions With Respect To Continued Russian Efforts To Undermine The Sovereignty And Territorial Integrity Of Ukraine. Similar to the existing embargo targeting the Crimea region of Ukraine, which Russia attempted to annex in 2014, the regulations prohibit:
OFAC issued the following general licenses authorizing certain limited dealings with the Covered Regions, including:
As a part of the EO and existing authorities, OFAC designated over 50 individuals, entities, and Russian vessels that operate or have operated in the financial services sector, technology sector, and defense and related materiel sector of the Russian economy and added them to the SDN List. FAQ 964 clarifies that a sector determination does not automatically impose sanctions on all persons who operate or have operated in the sector. Included in these measures are two financial institutions seen as crucial to financing the Russian defense industry along with their subsidiaries: Promsvyazbank Public Joint Stock Company (PSB), a Russian state-owned financial institution that is Russia’s eighth largest financial institution, and State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank (VEB), Russia’s national economic development institution. The measures also target elites close to Russian President Vladimir Putin viewed by the U.S. as President Putin’s inner circle, including Aleksandr Vasilievich Bortnikov, the Director of the Federal Security Service (FSB), and his son Denis Bortnikov, Petr Mikhailovich Fradkov, Chairman and CEO of PSB, and his son Vladimir Kiriyenko. |
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Commerce | Effective 2/24/22, Published 3/3/22 | 87 FR 12226 |
Summary of Change: |
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In response to the Russian Federation’s (Russia’s) further invasion of Ukraine, with this final rule, the Department of Commerce is adding new Russia license requirements and licensing policies to the Export Administration Regulations (EAR) to protect U.S. national security and foreign policy interests. These new Russia measures:
Lastly, this rule imposes comprehensive export, reexport and transfer (in- country) restrictions for the so-called Donetsk People’s Republic (DNR) and Luhansk People’s Republics (LNR) regions of Ukraine (“Covered Regions of Ukraine”) and makes conforming revisions to export, reexport transfer (in-country) restrictions for Crimea Region of Ukraine provisions. |
Agency: | Date: | Link to Notice: |
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Treasury | 2/24/22 | Refer to Summary of Change |
Summary of Change: |
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The Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Russia-related Directive 2 to impose correspondent and payable- through account sanctions on Russian financial institutions and listed Public Joint Stock Company Sberbank of Russia (Sberbank) and its subsidiaries under this directive. Additionally OFAC issued Directive 3 which prohibits U.S. persons from dealing in new equity and new debt from targeted entities. The impacted entities are large, Russian state- owned entities critical to the Russian economy, including Gazprombank, Gazprom, Gazprom Neft, and Sberbank. OFAC published new Frequently Asked Questions (regarding Russian Harmful Foreign Activities Sanctions) and updated several Frequently Asked Questions (including regarding sanctions applicable to Russian Harmful Foreign Activities, Belarus, Ukraine and Russia) . OFAC published a range of general licenses, intended to minimize unintended impacts on third parties. Russia-related
Belarus
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Agency: | Date: | Link to Notice: |
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Treasury | Effective 3/1/22 | 87 FR 11297 |
Summary of Change: |
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The Department of the Treasury’s Office of Foreign Assets Control (OFAC) added Russian Harmful Foreign Activities Sanctions Regulations (31 CFR part 587) to implement Executive Order 14024 from April 15, 2021. OFAC intends to supplement these regulations with a more comprehensive set of regulations, which may include additional interpretive guidance and definitions, general licenses, and other regulatory provisions. |
Agency: | Date: | Link to Notice: |
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White House | Published 3/2/22 | White House fact sheet |
Summary of Change: |
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This White House Fact Sheet on Russia and Belarus sanctions describes new sanction actions. More details will be published by agencies in coming days (see example below for Belarus). Actions described in the Fact Sheet include:
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Agency: | Date: | Link to Notice: |
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Commerce | For publication 3/8/22 | 15 CFR Parts 734, 736, 738, 740, 742, 744, and 746 |
Summary of Change: |
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In response to Belarus’s substantial enabling of the Russian Federation’s (Russia)’s further invasion of Ukraine, this rule is adding 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;
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. |