U.S. government agencies recently took steps to further restrict Russia’s ability to import critical technologies in response to its ongoing efforts to evade the multilateral sanctions and export controls imposed on Moscow for its invasion of Ukraine.
OFAC. The Treasury Department’s Office of Foreign Assets Control designated 25 individuals and 29 entities with touchpoints in 20 jurisdictions. These include a China-based supplier for multiple entities in Russia’s military-industrial complex, two Türkiye-based firms that have aided blocked entities and operated in Russia’s technology and electronics sectors, and two United Arab Emirates-based companies that have operated in Russia’s technology, electronics, or aerospace sectors.
According to a Reuters article, an unnamed U.S. official said the sanctions against non-Russian entities are “meant as a warning shot in the evolving phase of enforcing export controls.”
All property and interests in property of those designated that are in the U.S. or in the possession or control of U.S. persons are blocked and must be reported to OFAC. Any entities owned directly or indirectly 50 percent or more by one or more blocked persons are also blocked. All transactions by U.S. persons or within (or transiting) the U.S. that involve any property or interests in property of designated or blocked persons are prohibited unless authorized by a general or specific license issued by OFAC, or exempt. These prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any blocked person and the receipt of any contribution or provision of funds, goods, or services from any such person.
State. The State Department sanctioned several entities operating in Russia’s defense sector, entities supporting Russia’s war against Ukraine (including a new Russian private military company and a China-based firm that has provided satellite imagery of locations in Ukraine), and additional entities associated with Russia’s State Atomic Energy Corporation (because Russia uses energy exports, including in the nuclear sector, to exert political and economic pressure on customers globally).
BIS. The Bureau of Industry and Security has issued a final rule that, effective April 12, added 28 entities to the Entity List, including 12 in China, 10 in Russia, two each in the UAE and Uzbekistan, and one each in Armenia, Malta, Singapore, Spain, Syria, and Turkey. These entities were cited for attempting to evade controls on exports to Russia and other actions that have aided Russia’s military or defense industrial base.
For all of these entities BIS is imposing a license requirement for exports of all items subject to the Export Administration Regulations. BIS will review license applications for some of these entities under a policy of denial and for others under a presumption of denial.
For more information on these actions, please contact Kristine Pirnia at (202) 730-4964 or via email.
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