Morgan Lewis US and Russia Sanctions Update
What's Newest (cont'd)
OFAC related 2 March SDN designations announcement (and FSB GL amendment)
reflects SDN designations against the three institutes (per E.O. 13382) and seven gov't officials (per E.O.
13661) as stated in the above State Dep't announcement
issuance of cyber-related General License (GL) 1B, replacing former 1A, re permissible interactions with FSB
(which was already SDN designated); seems just some tightening of technical wording - see further slides
43-44
BIS actions
amendment of the Export Administration Rules (EAR), final rule published 4 March, to add 14 Russian,
German and Swiss entities (scientific/pharma-related) - including one above-designated RF Defense Ministry
Institute to the Entity List, which imposes license requirements on and limits availability of most license
exceptions for exports, reexports and in-country transfers involving such entities (see slides 29-30)
published announcement and rule effective 18 March
Pending/possible further sanctions laws (and see slides 69-70)
Likely further round from Biden Administration, for SolarWinds and related hacking of US gov't
and private computer systems, election interference, etc. - might include
<
further targeting Russian sovereign debt (ruble primary, USD secondary, both?)
some more oligarchs (but if so, likely not ones having internationally significant ownership holdings like
Deripaska or Vekselberg)
The mid-March US intelligence community assessment findings re election interference (and Biden
Admin. and congressional statements on that) need to be taken into account here
Early Feb. 2021 Senate bipartisan updated "Holding Russia Accountable for Malign Activities Act of
2021" bill introduced: focuses on imposition of array of Navalny-related sanctions, so may now be
moot (though also would require report on Nemtsov killing, and President Putin's/family's wealth)
Others? possible revival / adjustment / passage of DASKA Act (DASKAA - latest draft from Dec.
2019), and/or others on hold from 2020?
Morgan Lewis
60View entire presentation