Russia Sanctions: The UK designated 63 individuals this week, including several war correspondents embedded with Russian forces in Ukraine that work at Channel One, a major state-owned media outlet in Russia. The UK also designated one entity, Evraz PLC, a UK-incorporated holding company of a multinational steel manufacturing and mining company group. Additionally, the UK made several amendments regarding previously-designated individuals and entities.
There is media reporting that the EU is considering announcing a sixth round of sanctions against Russia, but no official announcements have been released. Still, a new package of sanctions is expected, barring material reduction of the Russian invasion of Ukraine.
General Licenses and Clarifications: The UK issued a general license to allow the continuation of business with the North American subsidiaries of the recently designated Evraz PLC until September 2, 2022.
The U.S. published three new general licenses (“GLs”) and updated two previously-issued GLs this week. The new general licenses authorize: (i) transactions with Gazprom Germania GmbH (and entities owned 50 percent or more by Gazprom Germania GmbH) until September 30, 2022; (ii) wind-down transactions with Amsterdam Trade Bank NV until July 12, 2022; and (iii) certain transactions in connection with patent, trademark, copyright, or other forms of intellectual property protection in the U.S. or Russia. The updated GLs: (i) added Sberbank Switzerland to GL 26A, which authorizes wind-down transactions until July 12, 2022; and (ii) clarified that GL 7A, which authorizes overflight payments, emergency landings, and air ambulance services in the Russian Federation, does not authorize any debit to an account on the books of a U.S. financial institution of the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation.
Export: The UK announced a ban on services exports to Russia. This will include a ban on providing management consulting, accounting, and public relations services to Russia, but the full scope of the services that will be covered has not been announced.
The EU removed Russia from all European Union general export authorizations. Previously exporters were able to utilize the following general export authorizations for exports to Russia: (i) EU003 for items that are re-exported after being repaired or replaced in the EU, (ii) EU004 for items that are temporarily exported for the purpose of an exhibition or fair, and (iii) EU005 for certain telecommunications items.
The U.S. issued several new FAQs clarifying its export regulations with respect to Russia and Belarus. These FAQs cover topics including: (i) licensing requirements, (ii) the license application review policy, (iii) the Foreign Direct Product Rule, (iv) the De Minimis Rules, (v) excluded countries, (vi) luxury goods, (vii) license exceptions, and (viii) updates to Country Group designations and the Country Chart.