Switzerland's State Secretariat for Economic Affairs on Nov. 1 amended 224 entries under its Russia sanctions regime. The updates were for 181 people and 43 entities and, for many, gave more specific reasons for the listings. The changes took effect Nov. 2.
The Guernsey Financial Services Commission on Nov. 1 called on companies to submit reports involving frozen assets linked to parties designated under the Russia sanctions list. Businesses that "hold or control frozen assets" of the sanctioned parties, "or which have an ongoing connection to frozen assets outside" Guernsey, should report certain information about those assets to the government by Nov. 24.
The House on Nov. 3 passed a bill that could lead to new primary and secondary sanctions on foreign ports and refineries that process or accept petroleum exported from or originating in Iran. The Stop Harboring Iranian Petroleum Act, passed 342-69, could also lead to sanctions on any entity that “transports, offloads, or otherwise deals in petroleum originating in Iran, including vessels engaging in ship-to-ship transfers of petroleum,” according to a press release from Rep. Mike Lawler, R-N.Y., who introduced the bill alongside Rep. Jared Moskowitz, D-Fla.
The Office of Foreign Assets Control last week sanctioned Ekaterina Zhdanova, a Russian national who the agency said has laundered money and moved funds on behalf of wealthy Russians using virtual currency.
As the EU implements its new import restrictions on Russian iron and steel, European companies are starting to ask U.S. exporters whether their products contain those Russian metals, said Scott Gearity, a consultant with the Export Compliance Training Institute. Gearity said most U.S. companies shouldn’t face any legal issues in making that certification, and Bailey Reichelt, a lawyer with Aegis Trade Law, stressed that companies don’t need to include an end-use statement as part of every benign contract, a practice that could scare potential customers that don’t deal in items subject to trade controls.
The U.S. this week announced a spate of new Russia-related sanctions and export controls, targeting people and companies supplying Russia’s military, aiding its defense industrial complex or operating in various Russian financial, metals, government and procurement sectors. The measures include additions to the Commerce Department’s Entity List and more than 200 combined sanctions by the Treasury and State departments targeting businesses in China, the United Arab Emirates and elsewhere for sending export-controlled components to Russia.
The U.K. corrected one entry under its Russia sanctions regime Oct. 31, removing an alias for Veniamin Ivanovich Kondratyev, governor of the Krasnodar territory.
The EU updated a frequently asked question under its Russia sanctions regime pertaining to the Central Bank of Russia. The question asked whether the payment to fulfill the "obligation to pay voluntary transaction" falls under the definition of "transactions related to the management of reserves as well as assets" under the bloc's sanctions regime. The EU said the Russian Governmental Commission sets the obligation to pay a voluntary transaction, or so-called "exit tax," which is not part of Russia's official tax legislation. Sanctions don't apply because payment is a "precondition for" allowing EU companies to divest from Russia and doesn't lead to "enabling the Russian Central Bank to manage its reserves or assets."
The Rotterdam District Court on Oct. 31 sentenced an unnamed Russian businessman to an 18-month prison term for violating the EU's Russia sanctions, according to an unofficial translation. The charges against the man include selling dual-use goods, including a "certain type of integrated circuit" and drones to Russian companies, along with selling, delivering, transferring and exporting nine other integrated circuit types to the same unnamed Russian companies.
A recent ruling by a U.K. appellate court “sent the sanctions legal community into a bit of a tailspin” after it appeared to pave the way for the government to treat every Russian public and private entity as a sanctioned party, said Daniel Martin, a sanctions lawyer with HFW. Although the U.K. has since clarified that its sanctions aren’t necessarily meant to apply to every Russian company, Martin said questions remain, including whether banks now will be even less willing to handle Russia-related transactions, whether U.K. lawyers will continue to be able to participate in Russian-related proceedings, and whether similar logic could apply to U.K. sanctions against other countries.