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Against Russia

Sanctions Against Russia have seen a cavalcade of Executive Orders and regulations targeting Russia’s government, entities and oligarchs. Their impact on the West has been large, too, as our institutions, companies and wealthy individuals have had to move quickly to respond to all the new legislation. Topics you can expect to hear more about at the conference include: 

  • In April 2022 OFAC placed full blocking sanctions on Russia’s largest banks Sberbank and Alfa-Bank. What is the impact for US and international banks and business?
  • The Whitehouse prohibited new investment in Russia. In comparison, -previously, with sanctions against China, the US government prohibited investments in the military-industrial business, defense and surveillance industry in China. But for Russia, this prohibition is not limited to any specific sector: it’s for any new investment in any sector. Some companies had already left Russia, like Spotify, Disney, Exxon Mobile, General Motors, but for the companies that stayed, will be faced with challenging compliance and operational issues.
  • What are the effects of cutting off Russia from SWIFT on Western entities? Limiting Russian banks’ ability to pay in dollars has impeded payments for goods and services. It does not make it impossible to do business with Russian entities, but it certainly makes it more difficult.
  • OFAC has turned its attention to precious metals involving wealthy Russians. Oligarchs are known to employ a variety of tactics to evade international sanctions. OFAC has made it clear it will prosecute US persons involved in transactions with blocked persons involving gold and other precious metals.
  • What general licenses can be used in this conflict? For example, OFAC’s general licenses authorize certain transactions involving foreign financial institutions subject to the prohibitions of the Russia-related CAPTA Directive, including deals related to the official business of international organizations; the exportation or re-exportation of agricultural commodities, medicine, medical devices, replacement parts and components, or software updates; the prevention, diagnosis, or treatment of COVID-19; and authorizing overflight payments, emergency landings, and air ambulance services.
  • An Executive Order of March 11, 2022, prohibits certain imports, exports, and new investments. These imports are “products of Russian Federation origin: fish, seafood, and preparations thereof; alcoholic beverages; non-industrial diamonds. It goes on to say ”any other products of Russian Federation origin as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State and the Secretary of Commerce.” That sounds like a potentially exhaustive list. Likewise, “luxury goods” exported from the US to Russia are prohibited and “any other items as may be determined by the Secretary of Commerce, in consultation with the Secretary of State and the Secretary of the Treasury, to any person located in the Russian Federation.” On the upside, specific licenses may authorize shipments after authorization deadlines expire.
  • Russian operators are turning more to cryptocurrencies, but we can’t quantify by how much because of their covert nature. How are they used to circumvent sanctions? What are the telltale signs?

There will be no shortage of topics awaiting discussion. Your knowledge of sanctions against Russia certainly stands to benefit.