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Sanctions/Export Highlights [As of September 1, 2022]


Russia Sanctions: This week the European Union designated three additional individuals.  Two of the individuals are members of the Duma who undermined the territorial integrity, sovereignty, and independence of Ukraine by voting in favor of a resolution regarding the need to recognize the so-called Donetsk People’s Republic and Luhansk People’s Republic.  The other sanctioned person is a member of the Federation Council, which ratified the “Treaty of Friendship, Cooperation and Mutual Assistance between the Russian Federation and the Donetsk People’s Republic and between the Russian Federation and the Luhansk People’s Republic.”

Enforcement: The U.S. Department of Commerce issued a charging letter alleging that PJSC LUKOIL (“Lukoil”), a Russian multinational oil and gas corporation, violated the Export Administration Regulations (“EAR”) by reexporting a U.S. origin Boeing 737-7EM aircraft to Russia without the required reexport license.  Relatedly, the U.S. Department of Justice (“DOJ”) obtained a warrant to seize the aircraft.  The forfeiture action was coordinated through the DOJ’s Task Force KleptoCapture which was created to enforce sanctions, export controls, and economic countermeasures that the United States imposed in response to Russia’s invasion of Ukraine.  The U.S. District Court for the Southern District of Texas issued the warrant.  The court found that the airplane was subject to seizure based on probable cause of violation of the EAR.  The airplane is estimated to be worth $45 million. 


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