Sanctions database

The U.S. Treasury officially announced the suspension of tax information exchange with Russia. It is further noted that no tax information has been exchanged with Russia since the invasion of Ukraine began on 24 February 2022. Link to the original

U.S. Department of the Treasury’s OFAC prohibited the Russian government from making payment to holders of its sovereign debt of more than $600 million from reserves held at U.S. banks that have been de facto frozen since late February. Sanctions imposed following Russia’s invasion of Ukraine on Feb. 24 had already frozen all foreign currency reserves held by the Central Bank of Russia with U.S. banks, but the Treasury Department had permitted Moscow to use those funds to meet coupon payment obligations on its dollar-denominated debt on a case-by-case basis.

Treasury has issued a new guidance indicating that transactions with the Central Bank of Russia involving gold may be sanctionable under E.O. 14024, which authorizes sanctions against persons using deceptive practices to circumvent sanctions, as well as persons operating in the financial sector of the Russian economy. This guidance makes clear that any transaction involving gold related to the Central Bank of Russia is covered by existing sanctions. Link to the original

OFAC, in consultation with the Department of State, issued a sectoral determination pursuant to E.O. 14024 that authorizes the imposition of economic sanctions on individuals and entities that operate or have operated in the aerospace, electronics, and marine sectors of Russian economy. Link to the original

Department of Commerce is imposing restrictions on the export, reexport, or transfer (in-country) to or within Russia or Belarus of ‘luxury goods’ under the Export Administration Regulations (EAR) and for exports, reexports and transfers (in-country) worldwide to certain Russian or Belarusian oligarchs and other malign actors supporting the Russian or Belarusian governments, In an effort to inform industry of the scope of goods that may be restricted, BIS regulations identify the luxury goods by Harmonized Tariff Number (HTSUS) and related descriptions. While still somewhat subject, since exporters are permitted to identify what HTSUS applies to the goods being exported, the list of items provides a specific framework against which companies can determine what is subject to restriction. Link to the original

The U.S. Treasury Department issued guidance spelling out how cryptocurrency should not be used to circumvent economic sanctions imposed against Russia. In a FAQ on whether Russia-related sanctions extend to virtual currency, the Department wrote that “U.S. persons, including virtual currency exchanges, virtual wallet hosts, and other service providers, such as those that provide nested services for foreign exchanges, are generally prohibited from engaging in or facilitating prohibited transactions, including virtual currency transactions in which blocked persons have an interest”. The FAQ said that U.S. persons are also barred from engaging in or facilitating prohibited transactions by a non-U.S. person, “including virtual currency transactions involving the Central Bank of the Russian Federation, National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation”. U.S. financial institutions are also generally prohibited from processing transactions, including virtual currency transactions, involving targeted financial institutions. Link to the original

U.K. Export Finance (UKEF), the Export-Import Bank of the United States (US EXIM), and Export Development Canada (EDC) have together withdrawn any new export finance support for the Russian Federation and Belarus, while retaining support for Ukraine. Link to the original

Prohibition on new investment in any sector of Russian economy as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State, by a US person, wherever located. E.O. 14068, which gave the Secretary of the Treasury the ability to add additional sectors to the investment ban. Link to the original

Prohibited the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of U.S. dollar-denominated banknotes to the Government of the Russian Federation or any person located in the Russian Federation. Link to the original

Prohibited any approval, financing, facilitation, or guarantee by a United States person, wherever located, of a transaction by a foreign person where the transaction by that foreign person would be prohibited by this section if performed by a United States person or within the United States, Link to the original