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Sanctions/Export Highlights [As of October 27, 2022]


New U.S. Designations: On October 26, 2022, the U.S. Department of the Treasury’s Office of Foreign Asset Control (“OFAC”) designated nine individuals and twelve entities for their involvement in the Russian Federation’s corruption and influence campaign in Moldova.  The designations included Igor Yuryevich Chayka, and Ivan Alesksandrovich Zavorotnyi, an associate of Chayka, for their actions related to election interference in Moldova.  Both men own various Russian-located entities, which were also designated.  In addition, OFAC designated Aleksei Valeryevich Troshin and the National Engineering Corporation (NIK) for their involvement in cybercrime.

EU Updates Guidance on Russian Sanctions: On October 24, 2022, the European Commission added five new FAQs to their guidance on business services prohibitions under the Russian Sanctions regime.  The new FAQs lay out the scope of prohibited activities classified under IT consultancy services, architectural and engineering services, and legal advisory services.  However, the Commission clarified that certain services “strictly necessary” for the termination of non-compliant contracts by January 8, 2023 are excluded from these prohibitions.  The new guidance additionally included a table providing an overview of prohibited services and any relevant exemptions.

EU Leaders Discuss Additional Sanctions on Iran and Belarus: Brussels hosted a summit for European Union leaders on October 20 and 21, 2022, where the European Council demanded Russia “immediately, completely, and unconditionally” withdraw all of its military forces from Ukraine.  The Council also called on Belarusian authorities to stop enabling Russian forces, noting that the EU remains ready to impose additional sanctions against Belarus if needed.  During the summit, European leaders also discussed imposing wider sanctions on Iran for its involvement in supplying weapons to Russia and for the ongoing civil rights abuses in Iran.

BIS Under Secretary Suggests Additional Export Controls on the Way: At an event hosted by the Center for a New American Security, Under Secretary of Commerce for Industry and Security Alan Estevez discussed the recent BIS controls aimed at restricting exports of advanced technologies to both China and Russia.  He noted that additional controls were likely to come “in the near term,” and would include a focus on emerging technologies, such as quantum information science, biotechnology, and artificial intelligence algorithms.


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