Morgan Lewis US and Russia Sanctions Update
What's Newest
United States
March 2021 multi-faceted sanctions packet re Navalny poisoning/imprisonment etc.
seems to have only limited effect on business (but more may come - see next slide)
State Dept. overarching 2 March announcement
new round of Chemical and Biological Weapons Act (CBW Act) sanctions:
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somewhat broadens the coverage scope and tightens exemptions (re exports of national security-sensitive items,
etc.) from what was already in place re the earlier Skripal poisoning - see slides 6 and 63-68
including new amendment of Int'l Traffic in Arms Regs. (ITAR) section 126.1 to include Russia in list of countries
subject to policy of denial for exports of defense articles and services (with exception in support of gov't, and
limited duration exception for commercial space cooperation)
CAATSA section 231(e) List of Specified Persons – six more Russian entities (all scientific / research
institutes - presumed to be connected with Russia's chemical weapons program) placed on it, such
that any person knowingly engaging in a significant transaction with any of them would be subject to
sanctions - see slides 51 and 54
E.O. 13382 sanctions (SDN designations) re weapons of mass destruction (WMD): against the FSB
and its head Alexander Bortnikov (re the Navalny poisoning), the Main Intelligence Directorate (GRU)
and the two GRU officers (re the 2018 Skripal poisoning - though they had already been designated
under other authorities), and three of the same institutes that were just targeted also for the section
231 List - see immediately above
E.O. 13661 sanctions (SDN designations): against seven senior Russian gov't officials (at Defense
Ministry, Presidential Executive Office, FSB (Bortnikov), Prosecutor General, and the Penitentiary
Service) - all for actual/presumed oversight involvement in the Navalny poisoning and imprisonment
some of the seven individuals having been sanctioned by the EU and UK in Oct. 2020 and some more by the EU in
March 2021 (see slides 83 and 85)
and, like EU, no designation of more oligarchs as Navalny had proposed be done
Morgan Lewis
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