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Summary of Recent OFAC Sanctions and BIS Export Controls on Russia, Belarus, and the Self-Declared Donetsk and Luhansk People’s Republics In Ukraine

March 29, 2022

Tahlia Townsend, Sean C. Koehler

In recent months, the United States has imposed a complex mix of economic sanctions and export controls on the Russia Federation, Belarus, and the Self-Declared Donetsk and Luhansk People’s Republics (DNR and LNR). In Wiggin and Dana’s Summary of Recent OFAC Sanctions and BIS Export Controls on Russia, Belarus, and the Self-Declared Donetsk and Luhansk People’s Republics in Ukraine we summarize and organize, in a series of at-a-glance tables, the tangled web of new controls implemented by the Department of Treasury, Office of Foreign Assets Control (OFAC) (economic sanctions) and the Department of Commerce, Bureau of Industry and Security (BIS) (export controls). Legal authorities covered in this Advisory are identified in the table below.

Wiggin and Dana’s International Trade Compliance Practice Group will continue to provide briefings as more information becomes available. For more information and advice regarding recent OFAC and BIS developments, contact partner Tahlia Townsend, co-chair of Wiggin and Dana’s International Trade Compliance practice group, at ttownsend@wiggin.com, or counsel Sean Koehler, skoehler@wiggin.com.

Legal Authorities Covered in Wiggin and Dana’s Summary of Recent OFAC Sanctions and BIS Export Controls on Russia, Belarus, and the Self-Declared Donetsk and Luhansk People’s Republics in Ukraine

AgencyLegal AuthorityDate
OFACExecutive Order 14065: Blocking Property of Certain Persons and Prohibiting Certain Transactions With Respect to Continued Russian Efforts To Undermine the Sovereignty and Territorial Integrity of UkraineFeb. 21, 2022
OFACAdditions to the SDN and Blocked Persons List dated Feb. 22, 2022; Feb. 23, 2022; Feb. 24, 2022; Feb. 25, 2022; Feb. 28, 2022; March 03, 2022; March 11, 2022; March 15, 2022; March 24, 2022Feb. 22, 2022 – March 24, 2022
OFACDirective 1A: Prohibitions Related to Certain Sovereign Debt of the Russian FederationFeb. 22, 2022
OFACDirective 2: Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial InstitutionsFeb. 24, 2022
OFACDirective 3: Prohibitions Related to New Debt and Equity of Certain Russia-related Entities  Feb. 24, 2022
OFACDirective 4: 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 FederationFeb. 28, 2022
OFACExecutive Order 14066: Prohibiting Certain Imports and New Investments With Respect to Continued Russian Federation Efforts To Undermine the Sovereignty and Territorial Integrity of UkraineMarch 8, 2022
OFACExecutive Order 14068: Prohibiting Certain Imports, Exports, and New Investment With Respect to Continued Russian Federation AggressionMarch 11, 2022
BISImplementation of Sanctions Against Russia Under the Export Administration Regulations (EAR)Feb. 24, 2022 
BISImposition of Sanctions Against Belarus Under the Export Administration Regulations (EAR)March 02, 2022
BISExpansion of Sanctions Against the Russian Industry Sector Under the Export Administration Regulations (EAR)March 03, 2022
BISFurther Imposition of Sanctions Against Russia with the Addition of Certain Entities to the Entity ListMarch 03, 2022
BISAddition to the List of Countries Excluded from Certain License Requirements under the Export Administration Regulations (EAR)March 04, 2022
BIS . . . .Imposition of Sanctions on ‘Luxury Goods’ Destined for Russia and Belarus and for Russian and Belarusian Oligarchs and Malign Actors Under the Export Administration Regulations (EAR) . . . .March 11, 2022

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