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Sanctions/Export Highlights [As of September 1, 2022]

By Jeffrey L. Snyder, Carlton Greene, Anand Sithian, Rachel Schumacher & Laurel Saito on September 5, 2022
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Russia Sanctions: This week the European Union designated three additional individuals.  Two of the individuals are members of the Duma who undermined the territorial integrity, sovereignty, and independence of Ukraine by voting in favor of a resolution regarding the need to recognize the so-called Donetsk People’s Republic and Luhansk People’s Republic.  The other sanctioned person is a member of the Federation Council, which ratified the “Treaty of Friendship, Cooperation and Mutual Assistance between the Russian Federation and the Donetsk People’s Republic and between the Russian Federation and the Luhansk People’s Republic.”

Enforcement: The U.S. Department of Commerce issued a charging letter alleging that PJSC LUKOIL (“Lukoil”), a Russian multinational oil and gas corporation, violated the Export Administration Regulations (“EAR”) by reexporting a U.S. origin Boeing 737-7EM aircraft to Russia without the required reexport license.  Relatedly, the U.S. Department of Justice (“DOJ”) obtained a warrant to seize the aircraft.  The forfeiture action was coordinated through the DOJ’s Task Force KleptoCapture which was created to enforce sanctions, export controls, and economic countermeasures that the United States imposed in response to Russia’s invasion of Ukraine.  The U.S. District Court for the Southern District of Texas issued the warrant.  The court found that the airplane was subject to seizure based on probable cause of violation of the EAR.  The airplane is estimated to be worth $45 million. 

Photo of Jeffrey L. Snyder Jeffrey L. Snyder

Since 1986, Jeff’s practice has concentrated on the U.S. regulation of international trade. Clients seek him out for troubleshooting and problem solving in cross-border transactions. Jeff advises on import, export, and sanctions laws. He develops approaches for multinationals to manage the impact of…

Since 1986, Jeff’s practice has concentrated on the U.S. regulation of international trade. Clients seek him out for troubleshooting and problem solving in cross-border transactions. Jeff advises on import, export, and sanctions laws. He develops approaches for multinationals to manage the impact of U.S. extraterritorial regulations. Jeff assists companies in day-to-day compliance with these laws, and with interventions — such as audits and investigations, and civil enforcement proceedings.

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Photo of Carlton Greene Carlton Greene

Carlton Greene is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade and White Collar & Regulatory Enforcement groups. He provides strategic advice to clients on U.S. economic sanctions, Bank Secrecy Act and anti-money laundering…

Carlton Greene is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade and White Collar & Regulatory Enforcement groups. He provides strategic advice to clients on U.S. economic sanctions, Bank Secrecy Act and anti-money laundering (AML) laws and regulations, export controls, and anti-corruption/anti-bribery laws and regulations. Carlton is the former chief counsel at FinCEN (the Financial Crimes Enforcement Network), the U.S. AML regulator responsible for administering the Bank Secrecy Act.

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Photo of Anand Sithian Anand Sithian

For high-stakes internal and government investigations and complex regulatory and compliance matters, companies and individuals look to Anand to provide strategic advice and counseling, particularly on issues relating to the Bank Secrecy Act and Anti-Money Laundering (“BSA/AML”), economic sanctions, and digital assets. Anand

…

For high-stakes internal and government investigations and complex regulatory and compliance matters, companies and individuals look to Anand to provide strategic advice and counseling, particularly on issues relating to the Bank Secrecy Act and Anti-Money Laundering (“BSA/AML”), economic sanctions, and digital assets. Anand is resident in the firm’s New York office and a member of the firm’s International Trade, White Collar and Regulatory Enforcement, and Financial Services groups.

A former federal prosecutor, Anand leverages his government experience to guide clients through complex white-collar matters, including grand jury and regulatory investigations, enforcement proceedings, and internal investigations. Anand has deep experience in parallel criminal and civil investigations and proceedings, and often represents clients in defending against civil lawsuits related to government investigations.

Representing some of the world’s largest banks and technology companies, Anand has addressed a wide range of issues, including economic sanctions, BSA/AML; economic sanctions and national security; payments and cryptocurrency; securities laws; and cybersecurity enforcement. In the regulatory space, Anand prides himself on providing commercial and actionable advice, including in the developing areas of digital assets, FinTech, and payments.

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Photo of Rachel Schumacher Rachel Schumacher

Rachel Schumacher is an associate in the International Trade and Government Contracts groups in Crowell & Moring’s Washington, D.C. office. Rachel’s practice focuses on transactions, investigations, and compliance and advisory matters involving a variety of government contracts and international trade issues.

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Photo of Laurel Saito Laurel Saito
Read more about Laurel SaitoEmail
  • Posted in:
    Government and Public Policy
  • Blog:
    International Trade Law
  • Organization:
    Crowell & Moring LLP
  • Article: View Original Source

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