Morgan Lewis US and Russia Sanctions Update
CBW Act Sanctions
Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 ("CBW
Act") and related EO 12851 of June 1993.
Newest imposition of CBW Act sanctions (per BIS published announcement and rule
effective 18 March 2021 (following from 2 March State Dep't release) - see slides 5
and 6) - for the Navalny poisoning (building on / overlapping with the 2018 and 2019
two rounds of such sanctions imposed for the Skripal poisoning, still in effect)
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Specific provisions (and notes re: (i) waivers of certain of these new restrictions; based on
national security, and (ii) comparison to the 2018-19 restrictions and waivers; and (iii) the
practical effect)
termination of assistance to Russia under the Foreign Assistance Act of 1961, except for urgent
humanitarian assistance and food/agricultural commodities etc. (already imposed in 2018 - little/no
practical effect)
termination of (a) sales to Russia under the Arms Export Control Act of any defense articles or services,
and (b) licenses/other approvals for export to Russia of any items on US Munitions List - except in
support of commercial space cooperation, but only for a six-month transition period (this is new), and
government space cooperation
termination of all foreign military financing for Russia under the Arms Export Control Act (same)
denial to Russia of any credit, credit guarantees, or other financial assistance by any dep't, agency or
instrumentality of the USG, including the US Eximbank (same)
prohibition on export to Russia of any goods or technology on that part of the control list established
under Section 2404(c)(1) of the Appendix to Title 50 - i.e., National Security (NS) controls (same)
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