Russia Sanctions Update Through October 14, 2022

U.S. sanctions chart. Highlights:

• As noted in the Friday email, OFAC, BIS, and State issued a joint alert summarizing U.S. sanctions against Russia (attached).
• OFAC also issued FAQ 1092, answering in the affirmative the question, “Do non-U.S. companies risk exposure to sanctions for providing ammunition or other military goods to Russia or for supporting Russia’s military-industrial complex?” (attached)
• DOJ announced the arrest of UK businessman Graham Bonham-Carter for conspiracy to violate U.S. sanctions imposed on Russian oligarch Oleg Deripaska and wire fraud.
• Russia’s decision to expropriate Exxon’s stake in the Sakhalin oil and gas project (see attached article) may encourage the U.S. Congress to pass legislation authorizing the seizure of Russian sovereign assets on deposit in the U.S. to repay U.S. companies for such expropriations (reference:Foreign Claims Settlement Commission of the United States) and to rebuild Ukraine.

International sanctions chart. Highlights:

• European Union
  • Council decision to mandate European Parliament negotiations on a decision on the non-acceptance of Russian travel documents issued in Ukraine and Georgia – “Russian travel documents issued in, or to persons resident in, Russian-occupied regions in Ukraine or breakaway territories in Georgia will not be accepted as valid travel documents for obtaining a visa or crossing the borders of the Schengen area.”
  • Council decision to add 30 individuals and 7 entities to list of EU sanctioned persons; these listings relate to the Ukraine ‘referendums’.
  • Council decision to expand the geographic scope of the EU’s restrictions against Russian controlled areas of Ukraine “to cover all non-government controlled areas of Ukraine in the oblasts of Dontesk, Kherson, Luhansk, and Zaporizhzhia.”
  • Council decision “that in event that a vessel under the flag of a third country has transported Russian crude oil or petroleum products purchased at a price above the price cap, it should be prohibited to provide technical assistance, brokering services, financing or financial assistance, including insurance, related to any transport in the future by that vessel of crude oil or petroleum products.”

• Switzerland
  • Decision to add 30 individuals and 7 entities to list of EU sanctioned persons; these listings relate to the Ukraine ‘referendums’.

PDF Documents Available Below

• Treasury-Commerce-State Alert_ Impact of Sanctions and Export Controls on Russia’s Military-Industrial Complex.pdf
• 1092 _ U.S. Department of the Treasury.pdf
• Russia Wipes Out Exxon’s Stake in Sakhalin Oil-and-Gas Project - WSJ.pdf