US Sectoral Sanctions

What's Newest (cont'd) 9 Sept. OFAC Settlement Agreement with a US affiliate of a leading European bank for processing various USD payments involving two SDN-designated entities under the Russia sanctions program: the bank's diligence lapses are highlighted 8 July OFAC Settlement Agreement with world-leading US e-commerce company for deliveries to customers in Crimea (and Iran and Syria) US Dep't of Justice announcement on 18 Nov. of guilty plea agreement with Russian company and its owner, for their part in conspiracy to evade Commerce Dep't-administered trade sanctions against Russia (see slides 27-28) - attempted export of American-made turbine for use in Russian Arctic offshore oil drilling This news follows the Dec. 2019 announced indictment of several Russian, Italian and US companies and persons (including the individual now convicted/sentenced) for this And announced June 2020 two years prison for Italian business owner convicted of being at the center of the conspiracy Some other latest OFAC enforcement actions teaching caution in/toward Russia (some involving exports/shipments through third country / front company to Russia (or other prohibited country or buyer - see slide 32) Some new SDN designations 23 Oct. designation of a Russian gov't research institute, under CAATSA section 224 (see slides 43 and 51 below), for deploying malware that has been targeting industrial safety systems in the US and elsewhere 23 Sept. designations of various entities and persons relating to (i) Yevgeniy Prigozhin's interests in Africa, and (ii) material/tech support for the FSB (Okeanos of Russia, and Optima Freight and others of Finland) 10 Sept. designations of an alleged Russian agent (member of Ukrainian parliament) and three Russians linked with the St. Petersburg-based IRA (already SDN-designated) for election interference See more at slide 43 below And more notable new secondary sanctions-related actions (again, not all relating to Russia - but to be kept in mind as fresh warnings) - see slides 11 and 44 See also July 2020 Senate committee report – The Art Industry and U.S. Policies That Undermine Sanctions And 19 Oct. 2020 US Justice Dept. announcement of criminal indictment of several individuals, including current and former Aeroflot employees, for smuggling over $50 million worth of US electronics goods from aboard Aeroflot flights from NY to Russia, in violation of US export control and other laws (not a sanctions case, but notable nonetheless) Morgan Lewis

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