U.S. Sanctions Against Russia and Belarus.xlsx


1	U.S. Russia OFAC Sanctions: Chronological List of Releases, Directives, and General Licenses as of October 30, 2022
2						Sources:	OFAC Recent Actions
3							Russian Harmful Foreign Activities Sanctions
4						Venable Client Alerts at bottom of chart
5	Date Issued	Effective Date	Expiration Date (GLs)	Update Date	Doc. #	Document Name	Summary

6	4/15/2021	4/15/2021			E.O. 14024	Executive Order Blocking Property With Respect To Specified Harmful Foreign Activities of the Government of the Russian Federation	Establishes a new national emergency under which sanctions may be imposed against individuals and entities furthering specified harmful foreign activities of Russia: its efforts to undermine democratic elections and institutions in the United States and its allies; engaging in malicious cyber-enabled activities against the United States and its allies; using transnational corruption to influence foreign governments; pursuing extraterritorial activities targeting dissidents or journalists; undermining security in countries and regions important to U.S. national security; and violating well-established principles of international law, including respect for the territorial integrity of states.
7	8/20/2021	8/20/2021			E.O. 14039	Blocking Property With Respect to Certain Russian Energy Export Pipelines	Blocks the property and interests in property of certain foreign persons that have sold, leased, provided, or facilitated the provision of vessels for the purpose of subsea pipe-laying activities related to the construction of Nord Stream 2 and TurkStream, or any successor pipeline, or that have provided underwriting services or insurance, or certain upgrades or installation services.
8	2/22/2022				Press Release	U.S. Treasury Imposes Immediate Economic Costs in Response to Actions in the Donetsk and Luhansk Regions	OFAC sanctioned 2 major Russian state-owned financial institutions and 42 of their subsidiaries crucial to financing the Russian defense industry: Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank (VEB) and Promsvyazbank Public Joint Stock Company (PSB). OFAC also imposed additional restrictions on Russian sovereign debt and sanctioned five Kremlin-connected elites.
9	2/22/2022	3/1/2022			Directive 1A	Prohibitions Related to Certain Sovereign Debt of the Russian Federation	Prohibits: (1) participation in the primary market for bonds issued after June 14, 2021 by the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation; (2) lending funds to the preceding entities as of June 14, 2021; and (3) participation in the secondary market for bonds issued after March 1, 2022 by the preceding entities.
10	2/22/2022	2/22/2022			General License 2	Authorizing Certain Servicing Transactions Involving State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank	Authorizes servicing of bonds issued before March 1, 2022 by the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation.
11	2/22/2022	2/22/2022	3/24/2022		General License 3	Authorizing the Wind Down of Transactions Involving State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank	Authorizes the wind down of transactions involving VEB, or any entity in which VEB owns (directly or indirectly) a 50 percent or greater interest through March 24, 2022 at 00:01 EDT.
12	2/22/2022	2/22/2022			Determination	Determination Pursuant to Section 1(a)(i) of Executive Order 14024	Determines that the economic sanctions imposed by E.O. 14024 shall apply to any person designated by Treasury or State who operates or has operated in the financial services sector of the Russian economy.
13	2/23/2022	2/23/2022			Recent Actions Notice	PEESA Designations; Issuance of Russia-related General License 4	OFAC sanctioned Matthias Warnig and Nord Stream 2 AG and authorized the wind down of transactions involving Nord Stream 2 AG.
14	2/23/2022	2/23/2022	3/2/2022		General License 4	Authorizing the Wind Down of Transactions Involving Nord Stream 2 AG	Authorizes the wind down of transactions involving Nord Stream 2 AG, or any entity in which Nord Stream 2 AG owns (directly or indirectly) a 50 percent or greater interest through March 2, 2022 at 00:01 EST.
15	2/24/2022				Press Release	U.S. Treasury Announces Unprecedented & Expansive Sanctions Against Russia, Imposing Swift and Severe Economic Costs	OFAC sanctioned Russia's two largest banks and almost 90 of their subsidiaries: Public Joint Stock Company Sberbank of Russia (Sberbank) and VTB Bank Public Joint Stock Company (VTB Bank). OFAC also sanctioned three additional major financial institutions: Public Joint Stock Company Bank Financial Corporation Otkritie (Otkritie), Open Joint Stock Company Sovcombank (Sovcombank), and Joint Stock Commercial Bank Novikombank (Novikombank). Finally, OFAC sanctioned additional Russian elites and their family members and imposed new prohibitions related to new debt and equity of major Russian state-owned enterprises and large privately owned financial institutions.
16	2/24/2022	3/26/2022			Directive 2	Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions	Prohibits U.S. financial institutions from: (1) opening or maintaining correspondent account or payable-through accounts for or on behalf of Sberbank and all foreign financial institution subsidiaries that are 50 percent or more owned (directly or indirectly) by Sberbank; and (2) processing transactions involving these entities.
17	2/24/2022	3/26/2022			Directive 3	Prohibitions Related to New Debt and Equity of Certain Russia-related Entities	Prohibit transactions and dealings by U.S. persons or within the United States in new debt of longer than 14 days maturity and new equity issued after March 26, 2022 at 00:01 EDT of 13 Russian state-owned enterprises and entities in the Russian financial services sector.
18	2/24/2022	2/24/2022			General License 5	Official Business of Certain International Organizations and Entities	Authorizes transactions related to the official business of certain international organizations and other entities.
19	2/24/2022	2/24/2022		3/24/2022	General License 6	Transactions Related to the Exportation or Reexportation of Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates, or the Coronavirus Disease 2019 (COVID-19) Pandemic	Authorizes transactions related to the exportation or reexportation of agricultural commodities, medicine, medical devices, replacement parts and components, or software updates, or the prevention, diagnosis, or treatment of COVID-19. Note that GL 6 was superseded and replaced in its entirety by GL 6A on March 24, 2022.
20	2/24/2022	2/24/2022		5/5/2022	General License 7	Authorizing Overflight Payments, Emergency Landings, and Air Ambulance Services	Authorizes overflight payments, emergency landings, and air ambulance services. Note that GL 7 was superseded and replaced in its entirety by GL 7A on May 5, 2022.
21	2/24/2022	2/24/2022	3/26/2022		General License 11	Authorizing the Wind Down of Transactions Involving Certain Blocked Persons	Authorizes the wind down of transactions involving Otkritie, Sovcombank, VTB Bank, or any entity in which the preceding entities own (directly or indirectly, individually or in the aggregate) a 50 percent or greater interest through March 26, 2022 at 00:01 EDT.
22	2/24/2022	2/24/2022	3/26/2022		General License 12	Authorizing U.S. Persons to Reject Certain Transactions	Authorizes U.S. persons to reject, rather than block, prohibited transactions involving Otkritie, Sovcombank, VTB Bank, or any entity in which the preceding persons own (directly or indirectly, individually or in the aggregate) a 50 percent or greater interest through March 26, 2022 at 00:01 EDT.
23	2/25/2022				Press Release	U.S. Treasury Imposes Sanctions on Russian Federation President Vladimir Putin and Minister of Foreign Affairs Sergei Lavrov	OFAC imposed sanctions on President Vladimir Putin and the Minister of Foreign Affairs, Sergei Lavrov, as well as other members of Russia’s Security Council.
24	2/28/2022				Press Release	Treasury Prohibits Transactions with Central Bank of Russia and Imposes Sanctions on Key Sources of Russia’s Wealth	OFAC prohibited U.S. persons from engaging in transactions with the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation. In addition, OFAC sanctioned three entities and one individual critical to managing one of Russia’s key sovereign wealth funds: Russian Direct Investment Fund (RDIF), its CEO, its management company, and one of the managing company’s subsidiaries.
25	2/28/2022	2/28/2022			Directive 4	Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation	Prohibits U.S. persons from engaging in any transaction involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation (the Directive 4 entities), including any transfer of assets to these entities or any foreign exchange transaction for or on behalf of these entities.
26	2/28/2022	2/28/2022	6/24/2022	4/6/2022	General License 8A	Authorizing Transactions Related to Energy Replaces General License 8, dated February 24, 2022	Authorizes certain transactions related to energy involving VEB, Otkritie, Sovcombank, Sberbank, VTB Bank, any entity in which one of the preceding persons owns (directly or indirectly, individually or in the aggregate) a 50 percent or greater interest, and the Central Bank of the Russian Federation through June 24, 2022 at 00:01 EDT. Note that GL 8A does not authorize transactions prohibited by E.O. 14066. Note that GL 8A was replaced and superseded in its entirety by GL 8B on April 6, 2022.
27	3/2/2022				Press Release	U.S. Treasury Takes Additional Steps to Strengthen Compliance with Russia-Related Sanctions	OFAC issued FAQs for enhanced compliance with U.S. sanctions and further explanation of recent sanctions actions, including Directive 4, E.O. 14065, and related general licenses. OFAC updated Russia-related guidance to allow U.S. financial institutions to continue processing energy-related transactions and underscore that sanctions do not prohibit such activity.
28	3/2/2022	3/2/2022	5/25/2022	4/6/2022	General License 9A	Authorizing Transactions Related to Dealings in Certain Debt or Equity Replaces General License 9, dated February 24, 2022	Authorizes: (1) transactions ordinarily incident and necessary to dealings in debt or equity issued before February 24, 2022 of VEB, Otkritie, Sovcombank, Sberbank, VTB Bank, or any entity in which a preceding entity owns (directly or indirectly, individually or in the aggregate) a 50 percent or greater interest, provided that any divestment or transfer of, or facilitation of divestment or transfer of, covered debt or equity must be to a non-U.S. person, through May 25, 2022 at 00:01 EDT; (2) transactions ordinarily incident and necessary to facilitating, clearing, and settling trades of covered debt or equity placed before February 24, 2022 at 16:00 EST, including debits to accounts on the books of U.S. financial institutions of the preceding entities, through May 25, 2022 at 00:01 EDT; and (3) transactions ordinarily incident and necessary to receive interest, dividend, or maturity payments on debt or equity of a Directive 4 entity through May 25, 2022 at 00:01 EDT. Note that GL 9A was replaced and superseded in its entirety by GL 9B on April 6, 2022.
29	3/2/2022	3/2/2022	5/25/2022	4/6/2022	General License 10A	Authorizing Certain Transactions Related to Derivative Contracts Replaces General License 10, dated February 24, 2022	Authorizes: (1) the wind down of derivative contracts entered into before February 24, 2022 at 16:00 EST that (a) include VEB, Otkritie, Sovcombank, Sberbank, VTB Bank, or any entity in which a preceding entity owns (directly or indirectly, individually or in the aggregate) a 50 percent or greater interest as a counterparty or (b) are linked to debt or equity of these entities, provided that any payments to a blocked person are made into a blocked account, through May 25, 2022 at 00:01 EDT, including debits to accounts on the books of U.S. financial institutions of these entities; and (2) the wind down of derivative contracts, repurchase agreements, or reverse repurchase agreements entered into before March 1, 2022 at 00:01 EST that include a Directive 4 entity as a counterparty through May 25, 2022 at 00:01 EDT. Please note that GL 10A was replaced and superseded in its entirety by GL 10B on April 6, 2022.
30	3/2/2022	3/2/2022	6/24/2022	5/25/2022	General License 13	Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024	Authorizes U.S. persons to pay taxes, fees, or import duties and purchase or receive permits, licenses, registrations, or certifications, to the extent such transactions are prohibited by Directive 4, provided such transactions are ordinarily incident and necessary to such persons’ day-to-day operations in Russia through June 24, 2022 at 00:01 EDT. Please note that GL 13 was replaced and superseded in its entirety by GL 13A on May 25, 2022.
31	3/2/2022	3/2/2022			General License 14	Authorizing Certain Clearing and Settlement Transactions Prohibited by Directive 4 under Executive Order 14024	Authorizes transactions involving the Directive 4 entities where the Directive 4 entity’s sole function is to act as an operator of a clearing and settlement system, provided that: (1) there is no transfer of assets to or from any Directive 4 entity, unless separately authorized; and (2) no Directive 4 entity is either a counterparty or a beneficiary to the transaction, unless separately authorized.
32	3/3/2022				Press Release	Treasury Sanctions Russians Bankrolling Putin and Russia-Backed Influence Actors	OFAC sanctioned numerous Russian elites and their family members, identified certain property of these persons as blocked, and sanctioned Russian intelligence-directed disinformation outlets.
33	3/3/2022	3/3/2022			General License 15	Authorizing Transactions Involving Certain Blocked Entities Owned by Alisher Burhanovich Usmanov	Authorizes transactions involving any entity owned 50 percent or more, directly or indirectly, by Alisher Burhanovich Usmanov that is not listed on OFAC’s Specially Designated Nationals and Blocked Persons List.
34	3/8/2022				Press Release	U.S. Treasury Guidance on President Biden’s Executive Order	OFAC released one general license and several FAQs to aid in the wind-down of deliveries of existing purchases of imported Russian oil, liquefied natural gas, and coal to the United States.
35	3/8/2022	3/8/2022			E.O. 14066	Executive Order on Prohibiting Certain Imports and New Investments With Respect to Continued Russian Federation Efforts to Undermine the Sovereignty and Territorial Integrity of Ukraine	Prohibits: (1) the importation into the United States of crude oil, petroleum, petroleum fuels, oils, products of petroleum fuels and oils' distillation, liquefied natural gas, coal, and coal products of Russian origin; (2) new investment in Russia's energy sector by a U.S. person, wherever located; and (3) any approval, financing, facilitation, or guarantee by a U.S. person, wherever located, of a transaction by a foreign person where the transaction would be prohibited if performed by a U.S. person or within the United States.
36	3/8/2022	3/8/2022	4/22/2022		General License 16	Authorizing Transactions Related to Certain Imports Prohibited by Executive Order of March 8, 2022 Prohibiting Certain Imports and New Investments With Respect to Continued Russian Federation Efforts to Undermine the Sovereignty and Territorial Integrity of Ukraine	Authorizes through April 22, 2022 at 00:01 EDT transactions ordinarily incident and necessary to the importation into the United States of crude oil, petroleum, petroleum fuels, oils, products of petroleum fuels and oils' distillation, liquefied natural gas, coal, and coal products of Russian origin pursuant to written contracts or agreements entered before March 8, 2022.
37	3/11/2022				Press Release	Treasury Sanctions Kremlin Elites, Leaders, Oligarchs, and Family for Enabling Putin’s War Against Ukraine	OFAC issued sanctions targeting Russian and Kremlin elites, oligarchs, and Russia’s political and national security leaders who have supported the Russian invasion of Ukraine. OFAC also issued guidance to guard against potential attempts to use virtual currency to evade U.S. sanctions imposed on Russia and to implement the new executive order that imposes new import and export restrictions on Russia, including the export of U.S. banknotes to Russia.
38	3/11/2022	3/11/2022			E.O. 14068	Executive Order on Prohibiting Certain Imports, Exports, and New Investment with Respect to Continued Russian Federation Aggression	Prohibits: (1) the importation into the United States of fish, seafood, preparations of fish and seafood, alcoholic beverages, and non-industrial diamonds of Russian origin, and any other products of Russian origin as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State and the Secretary of Commerce; (2) the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a U.S. person, wherever located, of luxury goods, 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 Russia; (3) new investment in any sector of the Russian economy as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State, by a U.S. person, wherever located; (4) the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a U.S. person, wherever located, of U.S. dollar-denominated banknotes to the Russian government or any person located in Russia; (5) any approval, financing, facilitation, or guarantee by a U.S. person, wherever located, of a transaction by a foreign person where the transaction by that foreign person would be prohibited if performed by a U.S. person or within the United States.
39	3/11/2022	3/11/2022	3/25/2022	3/24/2022	General License 17	Authorizing Transactions Related to Certain Imports Prohibited by Executive Order of March 11, 2022	Authorizes through March 25, 2022 at 00:01 EDT the importation into the United States of fish, seafood, preparations of fish and seafood, alcoholic beverages, and non-industrial diamonds of Russian origin pursuant to written contracts or agreements entered into before March 11, 2022. Note that GL 17 was superseded and replaced in its entirety by GL 17A on March 24, 2022.
40	3/11/2022	3/11/2022			General License 18	Authorizing U.S. Dollar-Denominated Banknote Noncommercial, Personal Remittances Prohibited by Executive Order of March 11, 2022	Authorizes the transfer of U.S. dollar-denominated banknotes for noncommercial, personal remittances from: (1) the United States or a U.S. person, wherever located, to an individual located in Russia; or (2) a U.S. person who is an individual located in Russia. Note that GL 18 does not authorize U.S. financial institutions to process transactions for the provision of U.S. dollar-denominated banknotes to foreign financial institutions for further distribution or supply to the Russian government or any person located in Russian.
41	3/11/2022	3/11/2022			General License 19	Authorizing Transactions Related to Personal Maintenance of U.S. Individuals Located in the Russian Federation Prohibited by Executive Order of March 11, 2022	Authorizes U.S. persons located in Russia to transfer U.S. dollar-denominated banknotes for transactions ordinarily incident and necessary to their personal maintenance within Russia.
42	3/15/2022				Press Release	Treasury Sanctions Russians Connected to Gross Human Rights Violations and Corrupt Leader of Belarus	OFAC sanctioned four individuals and one entity pursuant to the Russia Magnitsky Act for their involvement in concealing events surrounding the death of renowned Russian whistleblower Sergei Magnitsky or the gross violations of human rights against Russian human rights defender Oyub Titiev. In addition, the Secretary of State sanctioned 11 senior Russian defense officials.
43	3/24/2022				Press Release	U.S. Treasury Sanctions Russia’s Defense-Industrial Base, the Russian Duma and Its Members, and Sberbank CEO	OFAC sanctioned 48 Russian defense companies, 328 members of the Russian State Duma, and the CEO of Sberbank. OFAC also issued a new FAQ to clarify that any transaction involving gold related to the Central Bank of the Russian Federation is covered by existing sanctions.
44	3/24/2022				Recent Actions Notice	Issuance of Russia-related General Licenses; Publication of amended Frequently Asked Questions	OFAC issued three general licenses and updated two FAQs related to E.O. 14068.
45	3/24/2022	3/24/2022	3/25/2022; 6/23/2022		General License 17A	Authorizing Transactions Related to Certain Imports Prohibited by Executive Order 14068 Replaces General License 17, dated March 11, 2022	Authorizes: (1) through March 25, 2022 at 00:01 EDT the importation into the United States of alcoholic beverages and non-industrial diamonds of Russian origin pursuant to written contracts or agreements entered into before March 11, 2022; (2) through June 23, 2022 at 00:01 EDT the importation into the United States of fish, seafood, and fish and seafood preparations of Russian origin pursuant to written contracts or agreements entered into before March 11, 2022.
46	3/24/2022	3/24/2022		7/14/2022	General License 6A	Transactions Related to the Exportation or Reexportation of Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates, or the Coronavirus Disease 2019 (COVID-19) Pandemic, or Clinical Trials Replaces General License 6, dated February 24, 2022	Authorizes transactions related to: (1) the exportation or reexportation of agricultural commodities, medicine, medical devices, replacement parts and components, or software updates; (2) the prevention, diagnosis, or treatment of COVID-19; and (3) ongoing clinical trials and other medical research activities that were in effect before March 24, 2022. Note that GL 6A does not authorize transactions prohibited by E.O.s 14066 and 14068 and that it was superseded and replaced in its entirety by GL 6B on July 14, 2022.
47	3/24/2022	3/24/2022			General License 20	Authorizing Third-Country Diplomatic and Consular Funds Transfers	Authorizes U.S. persons to engage in transactions ordinarily incident and necessary to the official business of third-country diplomatic or consular missions located in Russia that are prohibited by E.O. 14024 or section 1(a)(iv) of E.O. 14068 (the bank note prohibition), except that it only permits the exportation, reexportation, sales, or supply of U.S. dollar-denominated bank notes to the Russian government for the payment of taxes or fees and the purchase or receipts of permits, licenses, or public utility services.
48	3/31/2022				Press Release	Treasury Targets Sanctions Evasion Networks and Russian Technology Companies Enabling Putin’s War	OFAC designated 21 entities and 13 individuals as part of its crackdown on the Kremlin’s sanctions evasion networks and technology companies, which are instrumental to Russia's war machine. Treasury has also determined that three new sectors of the Russian economy are subject to sanctions pursuant to E.O. 14024: aerospace, marine, and electronic.
49	3/31/2022	3/31/2022			Determination	Determination Pursuant to Section 1(a)(i) of Executive Order 14024	Determines that the economic sanctions imposed by E.O. 14024 shall apply to any person designated by Treasury or State who operates or has operated the aerospace, electronics, and marine sectors of the Russian economy.
50	4/5/2022				Press Release	Treasury Sanctions Russia-Based Hydra, World’s Largest Darknet Market, and Ransomware-Enabling Virtual Currency Exchange Garantex	OFAC sanctioned Hydra Market, the world’s largest and most prominent darknet market, and Garantex, a virtual currency exchange associated with illicit actors and darknet markets. OFAC also identified more than 100 virtual currency addresses associated with Hydra's operations that have been used to conduct illicit transactions.
51	4/6/2022				Press Release	U.S. Treasury Escalates Sanctions on Russia for Its Atrocities in Ukraine	OFAC imposed full blocking sanctions on Sberbank (and 42 of its subsidiaries) and Joint Stock Company Alfa-Bank (Alfa-Bank) (and 6 of its subsidiaries and 5 vessels owned by a subsidiary). OFAC also sanctioned family members of Russian President Vladimir Putin and Foreign Minister Sergey Lavrov, as well as Russian Security Council members. In addition, the President issued a new Executive Order banning new investment in Russia and the provision of certain services to any person located in Russia by U.S. persons, wherever located.
52	4/6/2022	4/6/2022			E.O. 14071	Executive Order on Prohibiting New Investment in and Certain Services to the Russian Federation in Response to Continued Russian Federation Aggression	Prohibits: (1) new investment in Russia by a United States person, wherever located; (2) the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of any category of services as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State, to any person located in Russia; and (3) any approval, financing, facilitation, or guarantee by a United States person, wherever located, of a transaction by a foreign person where the transaction would be prohibited if performed by a United States person or within the United States.
53	4/6/2022	4/6/2022	6/24/2022	6/14/2022	General License 8B	Authorizing Transactions Related to Energy Replaces General License 8A, dated February 28, 2022	Authorizes certain transactions related to energy involving VEB, Otkritie, Sovcombank, Sberbank, VTB Bank, Alfa-Bank, any entity in which one of the preceding persons owns (directly or indirectly, individually or in the aggregate) a 50 percent or greater interest, and the Central Bank of the Russian Federation through June 24, 2022 at 00:01 EDT. Note that GL 8B does not authorize transactions prohibited by E.O. 14066. Note that GL 8C was replaced and superseded in its entirety by GL 8C on June 14, 2022.
54	4/6/2022	4/6/2022	5/25/2022; 6/30/2022	4/7/2022	General License 9B	Authorizing Transactions Related to Dealings in Certain Debt or Equity Replaces General License 9A, dated March 2, 2022	Authorizes: (1) transactions ordinarily incident and necessary to dealings in debt or equity issued before February 24, 2022 of VEB, Otkritie, Sovcombank, Sberbank, VTB Bank, or any entity in which a preceding entity owns (directly or indirectly, individually or in the aggregate) a 50 percent or greater interest (Tranche 1 entity), provided that any divestment or transfer of, or facilitation of divestment or transfer of, this debt or equity must be to a non-U.S. person, through May 25, 2022 at 00:01 EDT; (2) transactions ordinarily incident and necessary to dealings in debt or equity issued before April 6, 2022 of Alfa-Bank or any entity in which Alfa-Bank owns (directly or indirectly) a 50 percent or greater interest (Alfa-Bank entity), provided that any divestment or transfer of, or facilitation of divestment or transfer of, this debt or equity must be to a non-U.S. person, through June 30, 2022 at 00:01 EDT; (3) transactions ordinarily incident and necessary to facilitating, clearing, and settling trades of Tranche 1 entity debt or equity placed before February 24, 2022 at 16:00 EST, including debits to accounts on the books of U.S. financial institutions of the Tranche 1 entities, through May 25, 2022 at 00:01 EDT; (4) transactions ordinarily incident and necessary to facilitating, clearing, and settling trades of covered Alfa-Bank entity debt or equity placed before April 6, 2022 at 16:00 EDT, including debits to accounts on the books of U.S. financial institutions of Alfa-Bank entities, through June 30, 2022 at 00:01 EDT; and (5) transactions ordinarily incident and necessary to receive interest, dividend, or maturity payments on debt or equity of a Directive 4 entity through May 25, 2022 at 00:01 EDT. Note that GL 9B was replaced and superseded in its entirety by GL 9C on April 7, 2022.
55	4/6/2022	4/6/2022	5/25/2022; 6/30/2022	4/7/2022	General License 10B	Authorizing Certain Transactions Related to Derivative Contracts Replaces General License 10A, dated March 2, 2022	Authorizes: (1) the wind down of derivative contracts entered into before February 24, 2022 at 16:00 EST that (a) includes a Tranche 1 entity as a counterparty or (b) are linked to debt or equity of these entities, provided that any payments to a blocked person are made into a blocked account, through May 25, 2022 at 00:01 EDT, including debits to accounts on the books of U.S. financial institutions of these entities; (2) the wind down of derivative contracts entered into before April 6, 2022 at 16:00 EDT that (a) includes an Alfa-Bank entity as a counterparty or (b) are linked to debt or equity of these entities, provided that any payments to a blocked person are made into a blocked account, through June 30, 2022 at 00:01 EDT, including debits to accounts on the books of U.S. financial institutions of these entities; and (3) the wind down of derivative contracts, repurchase agreements, or reverse repurchase agreements entered into before March 1, 2022 at 00:01 EST that include a Directive 4 entity as a counterparty through May 25, 2022 at 00:01 EDT. Note that GL 10B was replaced and superseded in its entirety by GL 10C on April 7, 2022.
56	4/6/2022	4/6/2022	6/7/2022	4/7/2022	General License 21	Authorizing the Wind Down of Sberbank CIB USA, Inc.	Authorizes the wind down of transactions involving Sberbank CIB USA, Inc. or any entity in which Sberbank CIB USA, Inc. owns (directly or indirectly) a 50 percent or greater interest, including the processing and payment of salaries, severance, and expenses; payments to vendors and landlords; and closing of accounts, through June 7, 2022 at 00:01 EDT. Note that GL 21 was replaced and superseded in its entirety by GL 21A on April 7, 2022.
57	4/6/2022	4/6/2022	4/13/2022		General License 22	Authorizing the Wind Down of Transactions Involving Public Joint Stock Company Sberbank of Russia	Authorizes the wind down of transactions involving Sberbank or any entity in which Sberbank owns (directly or indirectly) a 50 percent or greater interest through April 13, 2022 at 00:01 EDT.
58	4/6/2022	4/6/2022	5/6/2022		General License 23	Authorizing the Wind Down of Transactions Involving Joint Stock Company Alfa-Bank	Authorizes the wind down of transactions involving Alfa-Bank entities through May 6, 2022 at 00:01 EDT.
59	4/7/2022				Press Release	The United States Sanctions Major Russian State-Owned Enterprises	OFAC sanctioned Alrosa, a Russian state-owned enterprise and the world’s largest diamond mining company. The Department of State also redesignated Joint Stock Company United Shipbuilding Corporation (USC), as well as its subsidiaries and board members. USC is a Russian state-owned enterprise that develops and constructs the majority of the Russian military’s warships.
60	4/7/2022	4/7/2022	5/25/2022; 6/30/2022; 7/1/2022		General License 9C	Authorizing Transactions Related to Dealings in Certain Debt or Equity Replaces General License 9B, dated April 6, 2022	Authorizes: (1) transactions ordinarily incident and necessary to dealings in the following debt or equity, provided that any divestment or transfer of, or facilitation of divestment or transfer of, this debt or equity must be to a non-U.S. person: (a) debt or equity issued before February 24, 2022 of VEB, Otkritie, Sovcombank, Sberbank, VTB Bank, or any entity in which a preceding entity owns (directly or indirectly, individually or in the aggregate) a 50 percent or greater interest (Russian financial institution entities), through May 25, 2022 at 00:01 EDT; (b) debt or equity issued before April 6, 2022 of Alfa-Bank or any entity in which Alfa-Bank owns (directly or indirectly) a 50 percent or greater interest, through June 30, 2022 at 00:01 EDT; (c) debt or equity issued before April 7, 2022 of Public Joint Stock Company Alrosa or any entity in which Alrosa owns (directly or indirectly) a 50 percent or greater interest, through July 1, 2022 at 00:01 EDT; (2) transactions ordinarily incident and necessary to facilitating, clearing, and settling trades of debt or equity, including debits to accounts on the books of U.S. financial institutions: (a) of Russian financial institution entities placed before February 24, 2022 at 16:00 EST, through May 25, 2022 at 00:01 EDT; (b) Alfa-Bank entities placed before April 6, 2022 at 16:00 EDT, through June 30, 2022 at 00:01 EDT; (c) Alrosa entities placed before April 7, 2022 at 16:00 EDT, through July 1, 2022 at 00:01 EDT; and (3) transactions ordinarily incident and necessary to receive interest, dividend, or maturity payments on debt or equity of a Directive 4 entity through May 25, 2022 at 00:01 EDT.
61	4/7/2022	4/7/2022	5/25/2022; 6/30/2022; 7/1/2022		General License 10C	Authorizing Certain Transactions Related to Derivative Contracts Replaces General License 10B, dated April 6, 2022	Authorizes: (1) the wind down of derivative contracts that include the following entities as a counterparty or are linked to debt of equity of these entities, including debits to accounts on the books of U.S. financial institutions of these entities, provided that any payments to a blocked person are made into a blocked account: (a) Russian financial institution entities, for derivative contracts entered into before February 24, 2022 at 16:00 EST, through May 25, 2022 at 00:01 EDT; (b) Alfa-Bank entities, for derivative contracts entered into before April 6, 2022 at 16:00 EDT, through June 30, 2022 at 00:01 EDT; (c) Alrosa entities, for derivative contracts entered into before April 7, 2022 at 16:00 EDT, through July 1, 2022 at 00:01 EDT; and (2) the wind down of derivative contracts, repurchase agreements, or reverse repurchase agreements entered into before March 1, 2022 at 00:01 EST that include a Directive 4 entity as a counterparty, through May 25, 2022 at 00:01 EDT.
62	4/7/2022	4/7/2022	6/7/2022		General License 21A	Authorizing the Wind Down of Sberbank CIB USA, Inc. and Alrosa USA, Inc. Replaces General License 21, dated April 6, 2022	Authorizes the wind down of transactions involving Sberbank CIB USA, Inc., Alrosa USA Inc., or any entity in which Sberbank CIB USA, Inc. or Alrosa USA Inc. owns (directly or indirectly) a 50 percent or greater interest, including the processing and payment of salaries, severance, and expenses; payments to vendors and landlords; and closing of accounts, through June 7, 2022 at 00:01 EDT.
63	4/7/2022	4/7/2022	5/7/2022		General License 24	Authorizing the Wind Down of Transactions Involving Public Joint Stock Company Alrosa	Authorizes the wind down of transactions involving Alrosa entities through May 7, 2022 at 00:01 EDT.
64	4/7/2022	4/7/2022		5/8/2022	General License 25	Authorizing Transactions Related to Telecommunications and Certain Internet-Based Communications	Authorizes: (1) transactions ordinarily incident and necessary to the receipt or transmission of telecommunications involving Russia; and (2) the exportation or reexportation, sale, or supply (directly or indirectly) from the United States or by U.S. persons, wherever located, to Russia of services, software, hardware, or technology incident to the exchange of communications over the internet. Note that GL 25 does not authorize transactions prohibited by E.O.s 14066 or 14068 and that it was superseded and replaced in its entirety by GL 25A on May 8, 2022.
65	4/12/2022				Recent Actions Notice	Issuance of Russia-related General License 26	OFAC issued GL 26.
66	4/12/2022	4/12/2022		5/5/2022	General License 26	Authorizing the Wind Down of Transactions Involving Joint Stock Company SB Sberbank Kazakhstan or Sberbank Europe AG	Authorizes the wind down of transactions involving Joint Stock Company SB Sberbank Kazakhstan or Sberbank Europe AG, or any entity in which Joint Stock Company SB Sberbank Kazakhstan or Sberbank Europe AG owns (directly or indirectly) a 50 percent or greater interest through July 12, 2022 at 00:01 EDT. Note that GL 26 was superseded and replaced in its entirety by GL 26A on May 5, 2022.
67	4/19/2022				Recent Actions Notice	Publication of Fact Sheet on Preserving Agricultural Trade, Access to Communication, and Other Support to Those Impacted by Russia's War Against Ukraine; Issuance of Russia-related General License 27	OFAC issued a fact sheet entitled, "Preserving Agricultural Trade, Access to Communication, and Other Support to Those Impacted by Russia's War Against Ukraine." OFAC has also issued Russia-related General License 27 "Certain Transactions in Support of Nongovernmental Organizations' Activities."
68	4/19/2022	4/19/2022			General License 27	Certain Transactions in Support of Nongovernmental Organizations’ Activities	Authorizes transactions ordinarily incident and necessary to the following activities by nongovernmental organizations provided that the only involvement of blocked persons is the processing of funds by financial institutions blocked pursuant to E.O. 14024: (1) humanitarian projects to meet basic human needs in Ukraine or Russia; (2) democracy building in Ukraine or Russia; (3) education in Ukraine or Russia; (4) non-commercial development projects directly benefiting the people of Ukraine or Russia; and (5) environmental and natural resource protection in Ukraine or Russia.
69	4/20/2022				Press Release	U.S. Treasury Designates Facilitators of Russian Sanctions Evasion	OFAC designated entities and individuals involved in attempts to evade sanctions imposed by the United States and its international partners on Russia. OFAC designated Russian commercial bank Transkapitalbank (TKB) and a global network of more than 40 individuals and entities led by U.S.-designated Russian oligarch Konstantin Malofeyev, including organizations whose primary mission is to facilitate sanctions evasion for Russian entities. OFAC also designated companies operating in Russia's virtual currency mining industry, reportedly the third largest in the world. OFAC issued two general licenses related to TKB, including a wind down GL and a GL to continue for six months certain transactions that are destined for or originating from Afghanistan, in support of efforts to address the humanitarian crisis.
70	4/20/2022	4/20/2022	10/20/2022		General License 28	Authorizing Certain Transactions Involving Public Joint Stock Company Transkapitalbank and Afghanistan	Authorizes: (1) transactions involving TKB or any entity in which TKB owns (directly or indirectly) a 50 percent or greater interest that are ultimately destined for or originating from Afghanistan through October 20, 2022 at 00:01 EDT; and (2) U.S. financial institutions to operate correspondent accounts on behalf of the TKB entities for these transactions.
71	4/20/2022	4/20/2022	5/20/2022		General License 29	Authorizing the Wind Down of Transactions Involving Public Joint Stock Company Transkapitalbank	Authorizes the wind down of transactions involving TKB entities through May 20, 2022 at 00:01 EDT.
72	4/20/2022				Recent Actions Notice	Publication of Russia-related Frequently Asked Question	OFAC published a new FAQ about the obligations that operators of credit card systems have under the Russian Harmful Foreign Activities Sanctions Regulations, 31 C.F.R. part 587 (RuHSR), and the Belarus Sanctions Regulations, 31 C.F.R. part 548 (BSR), with regard to payment cards issued by sanctioned Russian financial institutions.
73	5/2/2022				Recent Actions Notice	Issuance of Russia-related General License 30	OFAC issued Russia-related General License 30, "Authorizing Transactions Involving Gazprom Germania GmbH Prohibited by Directive 3 under Executive Order 14024."
74	5/2/2022	5/2/2022		7/14/2022	General License 30	Authorizing Transactions Involving Gazprom Germania GmbH Prohibited by Directive 3 under Executive Order 14024	Authorizes transactions involving Gazprom Germania GmbH or any entity in which Gazprom Germania GmbH owns (directly or indirectly) a 50 percent or greater interest that are prohibited by Directive 3 through September 30, 2022 at 00:01 EDT. Note that GL30 was superseded and replaced in its entirety by GL 30A on July 14, 2022.
75	5/5/2022				Recent Actions Notice	Issuance of Russia-related General Licenses; Publication of new and amended Russia-related Frequently Asked Questions	OFAC issued Russia-related General License 7A, General License 26A, General License 31, and General License 32. In addition, OFAC published one new Frequently Asked Question and amended one Frequently Asked Question.
76	5/5/2022	5/5/2022			General License 7A	Authorizing Overflight Payments, Emergency Landings, and Air Ambulance Services Replaces General License 7, dated February 24, 2022	Authorizes overflight payments, emergency landings, and air ambulance services.
77	5/5/2022	5/5/2022	7/12/2022		General License 26A	Authorizing the Wind Down of Transactions Involving Joint Stock Company SB Sberbank Kazakhstan, Sberbank Europe AG, or Sberbank (Switzerland) AG Replaces General License 26, dated April 12, 2022	Authorizes the wind down of transactions involving Joint Stock Company SB Sberbank Kazakhstan, Sberbank Europe AG, Sberbank (Switzerland) AG or any entity in which Joint Stock Company SB Sberbank Kazakhstan, Sberbank Europe AG, or Sberbank (Switzerland) AG owns (directly or indirectly) a 50 percent or greater interest through July 12, 2022 at 00:01 EDT.
78	5/5/2022	5/5/2022			General License 31	Authorizing Certain Transactions Related to Patents, Trademarks, and Copyrights	Authorizes in the United States or Russia: (1) the filing and prosecution of any application to obtain a patent, trademark, copyright, or other form of intellectual property protection; (2) the receipt of a patent, trademark, copyright, or other form of intellectual property protection; (3) the renewal or maintenance of a patent, trademark, copyright, or other form of intellectual property protection; (4) the filing and prosecution of any opposition or infringement proceeding with respect to a patent, trademark, copyright, or other form of intellectual property protection, or the entrance of a defense to any such proceeding.
79	5/5/2022	5/5/2022	7/12/2022		General License 32	Authorizing the Wind Down of Transactions Involving Amsterdam Trade Bank NV	Authorizes the wind down of transactions involving Amsterdam Trade Bank NV or any entity in which Amsterdam Trade Bank NV owns (directly or indirectly) a 50 percent or greater interest through July 12, 2022 at 00:01 EDT.
80	5/8/2022				Press Release	U.S. Treasury Takes Sweeping Action Against Russia’s War Efforts	OFAC designated individuals and entities critical to Russia’s ability to wage war against Ukraine. These include the board members of two of Russia’s most important banks, a Russian state-owned bank and 10 of its subsidiaries, a state-supported weapons manufacturer, and three of Russia’s state-controlled television stations that generate revenue for the state. OFAC also took action to cut off access to services that are used by Russia and Russian elites to evade sanctions by identifying accounting, trust and corporate formation, and management consulting as categories of services that subject to sanctions under E.O. 14071 and E.O. 14024.
81	5/8/2022				Recent Actions Notice	Russia-related Designations and Designations Updates; Issuance of Russia-related General Licenses, Publication of Russia-related Frequently Asked Questions	OFAC issued Russia-related General License 25A, General License 33, General License 34, and General License 35. OFAC also published a Determination Pursuant to Section 1(a)(i) of Executive Order 14024 and a Determination Pursuant To Section 1(a)(ii) Of Executive Order 14071 as well as new Frequently Asked Questions.
82	5/8/2022	5/8/2022		6/2/2022	General License 25A	Authorizing Transactions Related to Telecommunications and Certain Internet-Based Communications Replaces General License 25, dated April 7, 2022	Authorizes, except for transactions involving Joint Stock Company Channel One Russia, Joint Stock Company NTV Broadcasting Company, or Television Station Russia-1: (1) transactions ordinarily incident and necessary to the receipt or transmission of telecommunications involving Russia; and (2) the exportation or reexportation, sale, or supply (directly or indirectly) from the United States or by U.S. persons, wherever located, to Russia of services, software, hardware, or technology incident to the exchange of communications over the internet. Note that GL 25A does not authorize transactions prohibited by E.O.s 14066 or 14068 and that it was superseded and replaced in its entirety by GL 25B on June 2, 2022.
83	5/8/2022	5/8/2022	6/7/2022		General License 33	Authorizing the Wind Down of Operations or Existing Contracts Involving Certain Blocked Entities	Authorizes the wind down of transactions involving Joint Stock Company Channel One Russia, Joint Stock Company NTV Broadcasting Company, Television Station Russia-1, or any entity in which Joint Stock Company Channel One Russia, Joint Stock Company NTV Broadcasting Company, or Television Station Russia-1 owns (directly or indirectly, individually or in the aggregate) a 50 percent or greater interest through June 7, 2022 at 00:01 EDT.
84	5/8/2022	5/8/2022	7/7/2022		General License 34	Authorizing the Wind Down of Accounting, Trust and Corporate Formation, and Management Consulting Services	Authorizes transactions ordinarily incident and necessary to the wind down of the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a U.S. person, wherever located, of accounting, trust and corporate formation, and management consulting services to any person located in Russia through July 7, 2022 at 00:01 EDT.
85	5/8/2022	5/8/2022	8/20/2022		General License 35	Authorizing Transactions Involving Credit Rating and Auditing Services	Authorizes transactions ordinarily incident and necessary to the wind down of the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a U.S. person, wherever located, of credit rating or auditing services to any person located in Russia through August 20, 2022 at 00:01 EDT.
86	5/8/2022	5/8/2022			Determination	Determination Pursuant to Section 1(a)(i) of Executive Order 14024	Determines that the economic sanctions imposed by E.O. 14024 shall apply to any person designated by Treasury or State who operates or has operated the accounting, trust and corporation formation services, and management consulting sectors of the Russian economy.
87	5/8/2022	6/7/2022			Determination	Determination Pursuant to 1(a)(ii) of Executive Order 14071: Prohibitions Related to Certain Accounting, Trust and Corporate Formation, and Management Consulting Services	Prohibits the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of accounting, trust and corporate formation, and management consulting services to any person located in Russia.
88	5/11/2022				Recent Actions Notice	Publication of amended Russia-related Frequently Asked Questions	OFAC updated FAQs 1034, 1035, and 1038.
89	5/25/2022				Recent Actions Notice	Issuance of Russia-related General License 13A	OFAC issued Russia-related General License 13A, "Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024."
90	5/25/2022	5/25/2022	9/30/2022		General License 13A	Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024 Replaces General License 13, dated March 2, 2022	Authorizes U.S. persons, or entities owned or controlled (directly or indirectly) by a U.S. person, to pay taxes, fees, or import duties and purchase or receive permits, licenses, registrations, or certifications, to the extent such transactions are prohibited by Directive 4, provided such transactions are ordinarily incident and necessary to such persons’ day-to-day operations in Russia through September 30, 2022 at 00:01 EDT.
91	6/2/2022				Press Release	U.S. Treasury Severs More Networks Providing Support for Putin and Russia’s Elites	OFAC took further action to degrade the key networks used by Russia’s elites, including President Vladimir Putin, to attempt to hide and move money and anonymously make use of luxury assets around the globe. It sanctioned a Kremlin-aligned yacht brokerage, several prominent Russian government officials, and a close Putin associate and money-manager, Sergei Roldugin, who is a custodian of President Putin’s offshore wealth, among others. In order to further tighten and enforce existing sanctions, OFAC also identified yachts and aircraft in which sanctioned Russian elites maintain interests.
92	6/2/2022	6/2/2022			Recent Actions Notice	Counter Narcotics Designations; Russia-related Designations and Update; Issuance of Russia-related General Licenses	OFAC issued Russia-related GL 25B, GL 36, GL 37 and GL 38 and updated the SDN list.
93	6/2/2022	6/2/2022		7/14/2022	General License 25B	Authorizing Transactions Related to Telecommunications and Certain Internet-Based Communications Replaces General License 25A, dated May 8, 2022	Authorizes, except for transactions involving Joint Stock Company Channel One Russia, Joint Stock Company NTV Broadcasting Company, Television Station Russia-1, or Limited Liability Company Algoritm: (1) transactions ordinarily incident and necessary to the receipt or transmission of telecommunications involving Russia; and (2) the exportation or reexportation, sale, or supply (directly or indirectly) from the United States or by U.S. persons, wherever located, to Russia of services, software, hardware, or technology incident to the exchange of communications over the internet. Note that GL 25B does not authorize transactions prohibited by E.O.s 14066 or 14068 and that it was replaced and superseded in its entirety by GL 25C on July 14, 2022.
94	6/2/2022	6/2/2022	8/31/2022		General License 36	Authorizing the Wind Down of Transactions Involving Public Joint Stock Company Severstal	Authorizes the wind down of transactions involving Public Joint Stock Company Severstal or any entity in which Public Joint Stock Company Severstal owns (directly or indirectly) a 50 percent or greater interest through August 31, 2022 at 00:01 EDT.
95	6/2/2022	6/2/2022	7/1/2022		General License 37	Authorizing the Wind Down of Transactions Involving Nord Gold PLC	Authorizes the wind down of transactions involving Nord Gold PLC or any entity in which Nord Gold PLC owns (directly or indirectly) a 50 percent or greater interest through July 1, 2022 at 00:01 EDT.
96	6/2/2022	6/2/2022		8/19/2022	General License 38	Authorizing Transactions Related to Pension Payments to U.S. Persons	Authorizes the processing of pension payments to U.S. persons, provided that the only involvement of blocked persons is the processing of funds by financial institutions blocked pursuant to E.O. 14024. Note that GL 38 was replaced and superseded in its entirety by GL 38A on August 19, 2022.
97	6/6/2022				Recent Actions Notice	Publication of new and amended Russia-related Frequently Asked Questions	OFAC issued new FAQs addressing the definition of "new investment" and amended other FAQs.
98	6/9/2022				Recent Actions Notice	Publication of new Russia-related Frequently Asked Questions	OFAC issued new FAQs addressing E.O. 14071 .
99	6/14/2022				Recent Actions Notice	Issuance of Russia-related General License 8C; Publication of amended Russia-related Frequently Asked Questions	OFAC issued Russia-related GL 8C. In addition, OFAC published amended Frequently Asked Questions related to GL 8C.
100	6/14/2022	6/14/2022	12/5/2022		General License 8C	Authorizing Transactions Related to Energy Replaces General License 8B, dated April 6, 2022	Authorizes certain transactions related to energy involving VEB, Otkritie, Sovcombank, Sberbank, VTB Bank, Alfa-Bank, any entity in which one of the preceding persons owns (directly or indirectly, individually or in the aggregate) a 50 percent or greater interest, and the Central Bank of the Russian Federation through December 5, 2022 at 00:01 EST. Note that GL 8C does not authorize transactions prohibited by E.O. 14066.
101	6/15/2022				Press Release	U.S. Sanctions Members of Russian Violent Extremist Group	OFAC designated two key supporters of the ethnically motivated violent extremist group known as the Russian Imperial Movement (RIM) pursuant to E.O. 13224, as amended. RIM was previously designated by the U.S. Department of State as a Specially Designated Global Terrorist (SDGT) organization on April 7, 2020 for having provided training for acts of terrorism. RIM and its supporters continue to exacerbate Russia’s war of aggression in Ukraine through their fundraising efforts.
102	6/17/2022				Press Release	U.S. Treasury Commends Unprecedented Censure of Russia by Financial Action Task Force	FATF members agreed to severely limit Russia's role and influence within the FATF. In particular, FATF members decided that Russia can no longer hold any leadership or advisory roles or take part in decision-making on standard-setting, FATF peer-review processes, governance and membership matters. Russia can also no longer provide assessors, reviewers or other experts for FATF peer-review processes. The FATF will monitor the situation and consider at each of its Plenary meetings whether grounds exist for modifying these restrictions.
103	6/28/2022				Press Release	U.S. Treasury Sanctions Nearly 100 Targets in Putin’s War Machine, Prohibits Russian Gold Imports	OFAC designated 70 entities, many of which are critical to Russia's defense industrial base, including State Corporation Rostec, the cornerstone of Russia’s defense, industrial, technology, and manufacturing sectors, as well as 29 Russian individuals. The designations were taken in tandem with the State Department, which is imposing sanctions on an additional 45 entities and 29 individuals. Included in the State Department’s action is the designation of Russian military units and the re-designation of Russia’s Federal Security Service (FSB). The Department of State further announced steps to impose visa restrictions on officials believed to have threatened or violated Ukraine’s sovereignty, territorial integrity, or political independence, including on more than 500 Russian military officers and on Russian officials involved in suppressing dissent. Concurrent with these sanctions, OFAC prohibited the importation of Russian gold into the United States.
104	6/28/2022				Recent Actions Notice	Russia-Related Designations and Designations Updates; Issuance of Russia-Related General Licenses and Related Frequently Asked Questions	OFAC issued Russia-Related GL 39, GL 40, GL 41, GL 42, and GL 43. OFAC also published a determination pursuant to E.O. 14068, as well as one new FAQ and one amended FAQ related to this determination. In addition, names have been added or updated to or removed from OFAC's SDN list or updated on the Sectoral Sanctions Identifications (SSI) list.
105	6/28/2022	6/28/2022	8/11/2022		General License 39	Authorizing the Wind Down of Transactions Involving State Corporation Rostec	Authorizes the wind down of any transaction involving State Corporation Rostec, or any entity blocked not earlier than June 28, 2022 in which State Corporation Rostec owns, directly or indirectly, a 50 percent or greater interest, through August 11, 2022 at 00:01 EDT, provided that any payment to a blocked person must be made into a blocked account.
106	6/28/2022	6/28/2022		8/2/2022	General License 40	Civil Aviation Safety	Authorizes transactions ordinarily incident and necessary to the provision, exportation, or reexportation of goods, technology, or services to ensure the safety of civil aviation involving one or more of the blocked entities listed in the Annex to this GL, provided that: (1) the aircraft is registered in a jurisdiction solely outside Russia; and (2) the goods, technology, or services that are provided, exported, or reexported are for use on aircraft operated solely for civil aviation purposes. Note that GL 50 does not relieve any person from compliance with any other federal laws or requirements of other federal agencies, including the BIS Export Administration Regulations. Note that GL 40 was replaced and superseded in its entirety by GL40A on August 2, 2022.
107	6/28/2022	6/28/2022	12/22/2022		General License 41	Authorizing Certain Transactions Related to Agricultural Equipment	Authorizes transactions ordinarily incident and necessary to the manufacture, sale, and maintenance, including the provision and receipt of warranty and maintenance services, of agricultural equipment, components, and spare parts produced by Nefaz Publicly Traded Company or Public Joint Stock Company Tutaev Motor Plant, or any entity in which Nefaz or Tutaev Motor Plant owns (directly or indirectly, individually or in the aggregate) a 50 percent or greater interest, provided that any payment to a blocked person must be made into a blocked account, through December 22, 2022 at 00:01 EST.
108	6/28/2022	6/28/2022			General License 42	Authorizing Certain Transactions with the Federal Security Service	Authorizes the transactions involving the FSB that are ordinarily incident and necessary to: (1) requesting, receiving, utilizing, paying for, or dealing in licenses, permits, certifications, or notifications issued or registered by the FSB for the importation, distribution, or use of information technology products in Russia, provided that (a) the exportation, reexportation, or provision of any goods or technology that are subject to the Export Administration Regulations is licensed or otherwise authorized by the Department of Commerce, and (b) the payment of any fees to the FSB for such licenses, permits, certifications, or notifications does not exceed $5,000 in any calendar year; (2) complying with law enforcement or administrative actions or investigations involving the FSB; (3) complying with rules and regulations administered by the FSB. Note that Cyber GL 1B also authorizes certain transactions with the FSB.
109	6/28/2022	6/28/2022			Determination	Determination Pursuant to Section 1(a)(i) of Executive Order 14068: Prohibitions Related to Imports of Gold of Russian Federation Origin	Prohibits importation into the U.S. of gold of Russian origin.
110	6/28/2022	6/28/2022	8/31/2022	8/2/2022	General License 43	Divestment or Transfer of Debt or Equity of, and Wind Down of Derivative Contracts Involving, Public Joint Stock Company Severstal or Nord Gold PLC	Authorizes transactions ordinarily incident and necessary to: (1) the divestment or transfer of debt or equity of Public Joint Stock Company Severstal, Nord Gold PLC , or any entity in which Severstal or Nord Gold owns (directly or indirectly, individually or in the aggregate) a 50 percent or greater interest, purchased before June 2, 2022 (“covered debt or equity”) through August 31, 2022 at 00:01 EDT, provided that any divestment or transfer, or facilitation of divestment or transfer, of covered debt or equity must be to a non-U.S. person; (2) the wind down of derivative contracts entered into before June 2, 2022, that (a) include as a counterparty Severstal or Nord Gold entities or (b) are linked to a covered debt or equity, provided that any payments to a blocked person are made into a blocked account, through August 31, 2022 at 00:01 EDT. Note that GL 43 was replaced and superseded in its entirety by GL 43A on August 2, 2022.
111	6/30/2022				Press Release	U.S. Treasury Blocks Over $1 Billion in Suleiman Kerimov Trust	OFAC announced it has issued a Notification of Blocked Property to Heritage Trust, a Delaware-based trust in which OFAC-designated Russian oligarch Suleiman Abusaidovich Kerimov holds a property interest.
112	7/14/2022				Press Release	Treasury Releases Fact Sheet on Food and Fertilizer-Related Authorizations Under Russia Sanctions; Expands General License Authorizing Agricultural Transactions	OFAC issued a fact sheet to further clarify that agricultural commodities (including fertilizer), agricultural equipment, or medicine relating to Russia are not the target of U.S. sanctions. It also expanded the agricultural and medical authorizations in GL 6B, including to agricultural equipment.
113	7/14/2022				Recent Actions Notice	Issuance of Russia-Related General Licenses and Amended Frequently Asked Questions; Publication of Food Security Fact Sheet on Russia Sanctions and Agricultural Trade; Russia-related Designation Removal	OFAC issued GL 6B, 25C, 30A, and 44 and amended three FAQs related to these GLs. OFAC also published a food security fact sheet called "Russia Sanctions and Agricultural Trade" and removed two Alfa-bank entities from the SDN list.
114	7/14/2022	7/14/2022			General License 6B	Transactions Related to Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates, the Coronavirus Disease 2019 (COVID-19) Pandemic, or Clinical Trials Replaces General License 6, dated February 24, 2022	Authorizes transactions related to: (1) the production, manufacturing, sale, or transport of agricultural commodities, agricultural equipment, medicine, medical devices, replacement parts and components, or software updates; (2) the prevention, diagnosis, or treatment of COVID-19; and (3) ongoing clinical trials and other medical research activities. Note that GL 6B does not authorize transactions prohibited by E.O.s 14066, 14068, or 14071, which include new investment in Russia and the importation into the U.S. of certain products of Russian origin, such as alcoholic beverages, fish, seafood, or preparations thereof.
115	7/14/2022	7/14/2022			General License 25C	Authorizing Transactions Related to Telecommunications and Certain Internet-Based Communications Replaces General License 25B, dated June 2, 2022	Authorizes, except for transactions involving Joint Stock Company Channel One Russia, Joint Stock Company NTV Broadcasting Company, Television Station Russia-1, Limited Liability Company Algoritm, New Eastern Outlook, or Oriental Review: (1) transactions ordinarily incident and necessary to the receipt or transmission of telecommunications involving Russia; and (2) the exportation or reexportation, sale, or supply (directly or indirectly) from the United States or by U.S. persons, wherever located, to Russia of services, software, hardware, or technology incident to the exchange of communications over the internet. Note that GL 25C does not authorize transactions prohibited by E.O.s 14066 or 14068.
116	7/14/2022	7/14/2022	12/16/2022		General License 30A	Authorizing Transactions Involving SEFE Securing Energy for Europe GmbH Prohibited by Directive 3 under Executive Order 14024 Replaces General License 30, dated May 2, 2022	Authorizes transactions involving SEFE Securing Energy for Europe GmbH (formerly known as Gazprom Germania GmbH) or any entity in which SEFE Securing Energy for Europe owns (directly or indirectly) a 50 percent or greater interest that are prohibited by Directive 3 through December 16, 2022 at 00:01 EST.
117	7/14/2022	7/14/2022			General License 44	Authorizing the Export or Reexport of Certain Accounting Services to U.S. Individuals Located in the Russian Federation	Authorizes all transactions ordinarily incident and necessary to the exportation, reexportation, sale, or supply, directly or indirectly, from the U.S., or by a U.S. person, wherever located, of tax preparation or filing services to any individual who is a U.S. person located in Russia.
118	7/22/2022				Recent Actions Notice	Issuance of Russia-Related General Licenses and Frequently Asked Questions; Russia-related Designation Update	OFAC issued GLs 45 and 46 and published two new FAQs and amended two FAQs related to these GLs. It also made one addition to the SDN list.
119	7/22/2022	7/22/2022	10/20/2022		General License 45	Authorizing Transactions Related to the Wind Down of Certain Financial Contracts Prohibited by Executive Order 14071	Authorizes all transactions prohibited by section (1)(a)(i) of EO 14071 that are incident and necessary to the wind down of financial contracts or other agreements that were entered into on or before June 6, 2022 and involved, or are linked to, debt or equity issued by an entity in Russia through October 20, 2022 at 12:01 EDT.
120	7/22/2022	7/22/2022			General License 46	Authorizing Transactions in Support of an Auction Process to Settle Certain Credit Derivative Transactions Prohibited by Executive Order 14071	Authorizes: (1) all transactions related to the establishment, administration, participation in, and execution of an auction process as announced by the EMEA Credit Derivatives Determination Committee (“the auction”) to settle credit derivative transactions with a reference entity of “the Russian Federation” and prohibited by section 1(a)(i) of EO 14071; (2) the purchase or receipt of debt obligations of Russia by U.S. persons prohibited by section 1(a)(i) of EO 14071 for the period beginning two business days before the announced date of the auction and ending eight business days after the auction concludes; and (3) all transactions ordinarily incident and necessary to facilitating, clearing, and settling the foregoing transactions that are prohibited by section 1(a)(i) of EO 14071.
121	7/29/2022				Press Release	Treasury Targets the Kremlin’s Continued Malign Political Influence Operations in the U.S. and Globally	OFAC, as part of a joint action with the DOJ, sanctioned two individuals and four entities that support the Kremlin’s global malign influence operations and election interference activities.
122	8/2/2022				Press Release	Treasury Sanctions Elites and Companies in Economic Sectors that Generate Substantial Revenue for the Russian Regime	OFAC, in tandem with the State Department, imposed a new round of sanctions targeting Kremlin-connected elites, a major multinational company, and a sanctions evasion operation, as well as one yacht.
123	8/2/2022				Recent Actions Notice	Russia-related Designations, Designations Updates, and Designation Removal; Issuance of Russia-related General Licenses; Publication of Russia-related Frequently Asked Questions	OFAC issued GLs 40A, 43A, 47, 48, and 49. OFAC also published three Frequently Asked Questions related to the new round of sanctions on Kremlin-connected elites.
124	8/2/2022	8/2/2022		8/3/2022	General License 40A	Civil Aviation Safety Replaces General License 40, dated June 28, 2022	Authorizes transactions ordinarily incident and necessary to the provision, exportation, or reexportation of goods, technology, or services to ensure the safety of civil aviation involving one or more of the blocked entities listed in the Annex to this GL, provided that: (1) the aircraft is registered in a jurisdiction solely outside Russia; and (2) the goods, technology, or services that are provided, exported, or reexported are for use on aircraft operated solely for civil aviation purposes. Note that GL 50 does not relieve any person from compliance with any other federal laws or requirements of other federal agencies, including the BIS Export Administration Regulations. Note that GL 40A was superseded and replaced in its entirety by GL 40B on August 3, 2022.
125	8/2/2022	8/2/2022	8/31/2022		General License 43A	Divestment or Transfer of Debt or Equity of, and Wind Down of Derivative Contracts Involving, Public Joint Stock Company Severstal or Nord Gold PLC Replaces General License 43, dated June 28, 2022	Authorizes transactions ordinarily incident and necessary to: (1) the divestment or transfer, or facilitation thereof, of debt or equity of Public Joint Stock Company Severstal, Nord Gold PLC , or any entity in which Severstal or Nord Gold owns (directly or indirectly, individually or in the aggregate) a 50 percent or greater interest, purchased before June 2, 2022 (“covered debt or equity”) to a non-U.S. person through August 31, 2022 at 00:01 EDT; (2) the wind down of derivative contracts entered into before June 2, 2022, that (a) include as a counterparty Severstal or Nord Gold entities or (b) are linked to a covered debt or equity, provided that any payments to a blocked person are made into a blocked account, through August 31, 2022 at 00:01 EDT. Authorizes the unblocking of covered debt or equity that was blocked on or after June 2, 2022 but before June 28, 2022 provided that the unblocked debt or equity is solely used to effect the transactions authorized in (1) and (2).
126	8/2/2022	8/2/2022	9/1/2022	8/3/2022	General License 47	Authorizing the Wind Down of Transactions Involving Certain Entities Blocked on August 2, 2022	Authorizes transactions ordinarily incident and necessary to the wind down of any transaction involving Skolkovo Foundation, Skolkovo Institute of Technology, Technopark Skolkovo Limited Liability Company, Federal State Institution of Higher Vocational Education Moscow Institute of Physics and Technology, Publichnoe Aktsionernoe Obschestvo Magnitogorskiy Metallurgicheskiy Kombinat, Joint Stock Company Government Transport Company, or any entity in which one or more of the preceding persons owns (directly or indirectly, individually or in the aggregate) a 50 percent or greater interest through September 1, 2022 at at 00:01 EDT, provided that any payment to a blocked person must be made into a blocked account. Note that GL 47 was superseded and its replaced in its entirety by GL 47A on August 3, 2022.
127	8/2/2022	8/2/2022	10/3/2022; 10/31/2022	8/3/2022	General License 48	Divestment or Transfer of Debt or Equity of, and Wind Down of Derivative Contracts Involving, Certain Entities Blocked on August 2, 2022	Authorizes transactions ordinarily incident and necessary to: (1) the divestment or transfer, or facilitation of the divestment or transfer, of debt or equity of Publichnoe Aktsionernoe Obschestvo Magnitogorskiy Metallurgicheskiy Kombinat, Joint Stock Company Government Transport Company, or any entity in which one or more of the preceding persons owns (directly or indirectly, individually or in the aggregate) a 50 percent or greater interest purchased before August 2, 2022 (“covered debt or equity”) to a non-U.S. person through October 3, 2022 at 00:01 EDT; (2) facilitating, clearing, and settling trades of covered debt or equity through October 31, 2022 at 00:01 EDT, provided that such trades were placed before August 2, 2022 at 16:00 EDT; and (3) the wind down of derivative contracts entered into before August 2, 2022, that (i) include a blocked person described in (1) as a counterparty or (ii) are linked to covered debt or equity through October 3, 2022 at 00:01 EDT, provided that any payments to a blocked person are made into a blocked account. Note that GL 48 was superseded and replaced in its entirety by GL 48A on August 3, 2022.
128	8/2/2022	8/2/2022	1/31/2023		General License 49	Authorizing the Wind Down of Transactions Involving MMK Metalurji Sanayi Ticaret Ve Liman Isletmeciligi Anonim Sirketi	Authorizes transactions ordinarily incident and necessary to the wind down of any transaction involving MMK Metalurji Sanayi Ticaret Ve Liman Isletmeciligi Anonim Sirketi, or any entity in which MMK Metalurji owns, directly or indirectly, a 50 percent or greater interest through January 31, 2023 at 00:01 EST, provided that any payment to a blocked person must be made into a blocked account.
129	8/3/2022				Recent Actions Notice	Issuance of Russia-related General Licenses	OFAC amended GLs 40A, 47, and 48 to clarify that the licenses apply to Joint Stock Company State Transportation Leasing Company. The previous GLs did not include the term "Leasing" in the company’s name. The GLs are otherwise unchanged.
130	8/3/2022	8/3/2022			General License 40B	Civil Aviation Safety	Authorizes transactions ordinarily incident and necessary to the provision, exportation, or reexportation of goods, technology, or services to ensure the safety of civil aviation involving one or more of the blocked entities listed in the Annex to this GL, provided that: (1) the aircraft is registered in a jurisdiction solely outside Russia; and (2) the goods, technology, or services that are provided, exported, or reexported are for use on aircraft operated solely for civil aviation purposes. Note that GL 50 does not relieve any person from compliance with any other federal laws or requirements of other federal agencies, including the BIS Export Administration Regulations. Note that GL 40A was replaced and superseded in its entirety by GL 40B on August 3, 2022.
131	8/3/2022	8/3/2022	9/1/2022		General License 47A	Authorizing the Wind Down of Transactions Involving Certain Entities Blocked on August 2, 2022 Replaces General License 47, dated August 2, 2022	Authorizes transactions ordinarily incident and necessary to the wind down of any transaction involving Skolkovo Foundation, Skolkovo Institute of Technology, Technopark Skolkovo Limited Liability Company, Federal State Institution of Higher Vocational Education Moscow Institute of Physics and Technology, Publichnoe Aktsionernoe Obschestvo Magnitogorskiy Metallurgicheskiy Kombinat, Joint Stock Company Government Transport Leasing Company, or any entity in which one or more of the preceding persons owns (directly or indirectly, individually or in the aggregate) a 50 percent or greater interest in through September 1, 2022 at at 00:01 EDT, provided that any payment to a blocked person must be made into a blocked account.
132	8/3/2022	8/3/2022	10/3/2022; 10/31/2022		General License 48A	Divestment or Transfer of Debt or Equity of, and Wind Down of Derivative Contracts Involving, Certain Entities Blocked on August 2, 2022	Authorizes transactions ordinarily incident and necessary to: (1) the divestment or transfer, or facilitation of the divestment or transfer, of debt or equity of Publichnoe Aktsionernoe Obschestvo Magnitogorskiy Metallurgicheskiy Kombinat, Joint Stock Company Government Transport Leasing Company, or any entity in which one or more of the preceding persons owns (directly or indirectly, individually or in the aggregate) a 50 percent or greater interest purchased before August 2, 2022 (“covered debt or equity”) to a non-U.S. person through October 3, 2022 at 00:01 EDT; (2) facilitating, clearing, and settling trades of covered debt or equity through October 31, 2022 at 00:01 EDT, provided that such trades were placed before August 2, 2022 at 16:00 EDT; and (3) the wind down of derivative contracts entered into before August 2, 2022, that (i) include a blocked person described in (1) as a counterparty or (ii) are linked to covered debt or equity through October 3, 2022 at 00:01 EDT, provided that any payments to a blocked person are made into a blocked account.
133	8/19/2022				Recent Actions Notice	Counter Narcotics Designations Removals; Transnational Criminal Organizations Designations Removals; Issuance of Russia-related General Licenses	OFAC issued GLs 38 and 50.
134	8/19/2022	8/19/2022			General License 38A	Authorizing Transactions Related to Pension Payments to U.S. Persons Replaces General License 38, dated June 2, 2022	Authorizes the processing of pension payments to U.S. persons or non-U.S. persons not located in Russia, provided that the only involvement of blocked persons is the processing of funds by financial institutions blocked pursuant to E.O. 14024.
135	8/19/2022	8/19/2022			General License 50	Authorizing the Closing of Individual Accounts at Financial Institutions Blocked Pursuant to Executive Order 14024	Authorizes transactions ordinarily incident and necessary to (i) the closing of an account of an individual, wherever located, who is not a blocked person (“the account holder”), held at a financial institution blocked pursuant to E.O. 14024, and (ii) the unblocking and lump sum transfer of all remaining funds and other assets in the account to the account holder, including to an account of the account holder held at a non-blocked financial institution.
136	9/2/2022				Recent Actions Notice	Updates Related to Price Cap on Russian Oil	OFAC announced that it plans to release preliminary guidance on the implementation of the price cap on Russian crude oil and petroleum products later in September in advance of formal guidance and legal implementation.
137	9/8/2022	9/8/2022	12/7/2022		General License 13B	Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024	Authorizes taxes to pay taxes, fees, or import duties, and purchase or receive permits, licenses, registrations, or certifications, to the extent such transactions are prohibited by Directive 4 under Executive Order (E.O.) 14024, Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation, provided such transactions are ordinarily incident and necessary to the day-to-day operations in the Russian Federation of such U.S. persons or entities, through 12:01 a.m. eastern standard time, December 7, 2022.
138	9/9/2022				Press Release	Remarks by Deputy Secretary of the Treasury Wally Adeyemo at the Brookings Institution	Deputy Secretary of Treasury Wally Adeyemo made remarks at the Brookings Institution regarding the price cap on Russian oil. He explained that the cap is designed to keep Russian oil flowing to the global market without allowing the price to rise, reducing the risk of economic and political instability around the world. He announced that OFAC was issuing preliminary guidance on implementing the price cap.
139	9/9/2022	12/5/2022; 2/5/2023	12/8/2022		Recent Actions Notice	Preliminary Guidance on Implementation of a Maritime Services Policy and Related Price Exception for Seaborne Russian Oil	As part of a coalition of countries including the G7 and the EU, the United States will implement a policy with regards to a broad range of services related to the maritime transportation (the “maritime services policy”) of Russian Federation origin crude oil and petroleum products (“seaborne Russian oil”). This ban will take effect on December 5, 2022 with respect to maritime transportation of crude oil and on February 5, 2023 with respect to maritime transportation of petroleum products. This policy, constructed as a ban on services, will have an important exception: jurisdictions or actors that purchase seaborne Russian oil at or below a price cap to be established by the coalition (the “price exception”) will expressly be able to receive such services. This policy is intended to expressly establish a framework for Russian oil to be exported by sea under a capped price and achieve three objectives: (i) maintain a reliable supply of seaborne Russian oil to the global market; (ii) reduce upward pressure on energy prices; and (iii) reduce the revenues the Russian Federation earns from oil after its own war of choice in Ukraine has inflated global energy prices.
140	9/15/2022				Press Release	Treasury Targets Additional Facilitators of Russia’s Aggression in Ukraine	OFAC designated 22 individuals and 2 entities, including multiple individuals who have furthered Russian objectives in Ukraine, as well as Task Force Rusich, a neo-Nazi paramilitary group that has participated in combat alongside Russia’s military in Ukraine, and two of its senior leaders. OFAC also published a FAQ to provide additional guidance on the heightened risk of facilitating Russia’s efforts to evade sanctions through the expanded use of the National Payment Card System (NSPK) or the Mir National Payment System. In addition, OFAC published a determination pursuant to E.O. 14071 prohibiting the exportation, reexportation, sale, or supply, directly or indirectly, from the U.S., or by a U.S. person, wherever located, of quantum computing services to any person located in Russia. In conjunction with this determination, OFAC issued new guidance and identified the quantum computing sector of the Russian Federation economy pursuant to E.O. 14024.
141	9/15/2022				Recent Actions Notice	Russia-related Designations; Issuance of Russia-related General License and Frequently Asked Questions; Zimbabwe-related Designation, Removals and Update; Libya-related Designation Update	OFAC issued GL 51, published three FAQs, and updated the SDN list.
142	9/15/2022				Recent Actions Notice	Publication of Russia-related Determinations and Frequently Asked Questions	OFAC published a Determination Pursuant to Section 1(a)(i) of Executive Order 14024, a Determination Pursuant to Section 1(a)(ii) of Executive Order 14071, four related FAQs (1083-1086), and five amended FAQs (1033, 1034, 1059, 1061, 1062)
143	9/15/2022				Recent Actions Notice	Issuance of Russia-related General License	OFAC issued GL 52.
144	9/15/2022	9/15/2022			Determination	Determination Pursuant to Section 1(a)(i) of Executive Order 14024	Determines that the economic sanctions imposed by E.O. 14024 shall apply to any person designated by Treasury or State who operates or has operated in the quantum computing sector of the Russian economy.
145	9/15/2022	10/15/2022			Determination	Determination Pursuant to Section 1(a)(ii) of Executive Order 14071: Prohibitions Related to Certain Quantum Computing Services	Prohibits the exportation, reexportation, sale, or supply, directly or indirectly, from the U.S., or by a U.S. person, wherever located, of quantum computing services to any person located in Russia except: (1) any service to an entity located in Russia that is owned or controlled, directly or indirectly, by a U.S. person or (2) any service in connection with the wind down or divestiture of an entity located in Russia that is not owned or controlled, directly or indirectly, by a Russian person.
146	9/15/2022	9/15/2022	10/15/2022		General License 51	Authorizing the Wind Down of Transactions Involving Limited Liability Company Group of Companies Akvarius	Authorizes transactions ordinarily incident and necessary to the wind down of any transaction involving Limited Liability Company Group of Companies Akvarius (Aquarius), or any entity in which Aquarius owns, directly or indirectly, a 50 percent or greater interest through October 15, 2022 at 00:01 EDT.
147	9/15/2022	9/15/2022			General License 52	Journalistic Activities and Establishment of News Bureaus	Authorizes, except for transactions involving Joint Stock Company Channel One Russia, Joint Stock Company NTV Broadcasting Company, Television Station Russia-1, Limited Liability Company Algoritm, New Eastern Outlook, or Oriental Review, news reporting organizations that are U.S. persons, and individual U.S. persons who are journalists (including photojournalists) or broadcast or technical personnel, are authorized to engage in the following transactions, where such transactions are ordinarily incident and necessary to such U.S. persons’ journalistic activities or to the establishment or operation of a news bureau: (1) compensating support staff (e.g., stringers, translators, interpreters, camera operators, technical experts, freelance producers, or drivers), persons to handle logistics, or other office personnel; (2) leasing or renting office space; (3) purchasing, leasing, or renting goods and services (e.g., mobile phones and related airtime); or (4) paying for all other expenses ordinarily incident and necessary to journalistic activities, including sales or employment taxes.
148	9/30/2022				Press Release	Treasury Imposes Swift and Severe Costs on Russia for Putin’s Purported Annexation of Regions of Ukraine	In response to Russia's sham referenda, purported annexation, and occupation of the Kherson, Zaporizhzhya, Donetsk, and Luhansk regions of Ukraine, OFAC designated 14 persons in Russia’s military-industrial complex, including 2 international suppliers, 3 key leaders of Russia’s financial infrastructure, immediate family members of some senior Russian officials, and 278 members of Russia’s legislature for enabling Russia’s sham referenda and attempt to annex sovereign Ukrainian territory. In addition, OFAC issued new guidance that warns of the heightened sanctions risk that international actors outside of Russia would face for providing political or economic support to Russia as a result of its illegal attempts to change the status of Ukrainian territory, including an FAQ that clarifies that OFAC is prepared to more aggressively use its existing sanctions authorities.
149	9/30/2022				Recent Actions Notice	Russia-related Designations and Designations Updates; Publication of Russia-related Frequently Asked Question	OFAC published a Russia-related FAQ (1091) and updated the SDN List.
150	10/14/2022				Recent Actions Notice	Publication of a Russia-related Alert: Impact of Sanctions and Export Controls on Russia’s Military-Industrial Complex; Publication of Russia-related Frequently Asked Question	OFAC published a Russia-related alert, jointly with BIS and State, regarding the impact of U.S. sanctions and export controls on Russia's military-industrial complex. OFAC also published a Russia-related FAQ (1092) about whether U.S. sanctions reach non-U.S. companies providing ammunition or other military goods to Russia or otherwise supporting Russia's military-industrial complex.
151	10/19/2022				Press Release	Treasury Sanctions Russian Military Technology Procurement Network in Coordination with Law Enforcement Action	OFAC designated, in coordination with the DOJ, a Russian network that procured military and sensitive dual-use technologies from U.S. manufacturers, including advanced semiconductors and microprocessors used in fighter aircraft, ballistic and hypersonic missile systems, smart munitions, radar, satellites, and other military applications, and supplied them to Russian end-users.
152	10/19/2022				Recent Actions Notice	Russia-related Designations	OFAC added one individual and two entities to the SDN List.
153	10/26/2022				Press Release	Treasury Targets Corruption and the Kremlin’s Malign Influence Operations in Moldova	OFAC imposed sanctions on nine individuals and 12 entities, including oligarchs widely recognized for capturing and corrupting Moldova’s political and economic institutions and those acting as instruments of Russia’s global influence campaign, which seeks to manipulate the United States and its allies and partners, including Moldova and Ukraine
154	10/26/2022				Recent Actions Notice	Iran-related Designations; Russia-related Designations; Global Magnitsky Designation	OFAC updated the SDN list.
155
156	Venable client alerts						U.S. Responds to Putin’s Recognition of Separatist Republics in Eastern Ukraine (Feb. 22, 2022)
157							U.S. Treasury Imposes Second Round of Economic Sanctions Following Russian Takeover of Eastern Ukraine Regions (Feb. 23, 2022)
158							U.S. Sanctions Against Russia: Summary as of Tuesday, March 1, 2022 (March 2, 2022)
159							Treasury Expands Russia-Related General Licenses and Sanctions Against Russian Individuals and Entities (March 8, 2022)
160							Russia and Sanctions: What Happens Next? Compliance and Enforcement (March 14, 2022)
161							U.S. Economic Sanctions: Enforcement Strategy Against Russia Takes Shape (March 25, 2022)
162							Russia Sanctions: The U.S. Government Leans In (April 12, 2022)


1	U.S. Ukraine OFAC Sanctions: Chronological List of Releases, Directives, and General Licenses as of October 30, 2022
2						Sources:	OFAC Recent Actions
3							Ukraine-/Russia-related Sanctions
4						Venable Client Alerts at bottom of chart
5	Date Issued	Effective Date	Expiration Date (GLs)	Update Date	Doc. #	Document Name	Summary

6	2/21/2022				Recent Actions Notice	Issuance of Executive Order Blocking Property Of Certain Persons And Prohibiting Certain Transactions With Respect To Continued Russian Efforts To Undermine The Sovereignty And Territorial Integrity Of Ukraine; Issuance of Ukraine-related General Licenses	OFAC issued six general licenses authorizing certain transactions in the Donetsk People’s Republic (DNR) and Luhansk People’s Republic (LPR) regions of Ukraine (the Covered Regions).
7	2/21/2022	2/21/2022			E.O. 14065	Blocking Property of Certain Persons and Prohibiting Certain Transactions With Respect to Continued Russian Efforts To Undermine the Sovereignty and Territorial Integrity of Ukraine	Prohibits: (1) new investment in the DNR and LPR by a U.S. person, wherever located; (2) the importation into the United States, directly or indirectly, of any goods, services, or technology from these regions; (3) the exportation, reexportation, sale, or supply, directly or indirectly, from the United States or by a U.S. person, wherever located, of any goods, services, or technology to these regions; and (4) any approval, financing, facilitation, or guarantee by a U.S. person, wherever located, of a transaction by a foreign person where the transaction would be prohibited if performed by a U.S. person, or within the United States. Authorizes sanctions against persons that: (1) operate or have operated in these regions since February 21, 2022; (2) are or have been a leader, official, senior executive officer, or member of the board of directors since February 21, 2022 of an entity operating in these regions; (3) are owned or controlled by, or to have acted or purported to act for or on behalf of, directly or indirectly, any person whose property and interests in property are blocked pursuant to this E.O.; or (4) have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, any person whose property and interests in property are blocked pursuant to this E.O.
8	2/21/2022		3/23/2022		General License 17	Authorizing the Wind Down of Transactions Involving the So-called Donetsk People’s Republic or Luhansk People’s Republic Regions of Ukraine	Authorizes the wind down of transactions involving the DNR and LNR regions of Ukraine through March 23, 2022 at 00:01 EDT.
9	2/21/2022	2/21/2022			General License 18	Authorizing the Exportation or Reexportation of Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates to Certain Regions of Ukraine and Transactions Related to the Coronavirus Disease 2019 (COVID-19) Pandemic	Authorizes certain transactions that are ordinarily incident and necessary to: (1) the exportation or reexportation of agricultural commodities, medicine, medical devices, replacement parts and components for medical devices, or software updates for medical devices to the Covered Regions, or to persons in third countries purchasing specifically for resale to the Covered Regions; or (2) the prevention, diagnosis, or treatment of COVID-19 (including research or clinical studies relating to COVID-19).
10	2/21/2022	2/21/2022			General License 19	Authorizing Transactions Related to Telecommunications and Mail	Authorizes: (1) certain transactions related to telecommunications that are ordinarily incident and necessary to the receipt or transmission of telecommunications in the Covered Regions; and (2) certain transactions of common carriers involving the Covered Regions that are ordinarily incident and necessary to the receipt or transmission of mail and packages.
11	2/21/2022	2/21/2022			General License 20	Official Business of Certain International Organizations and Entities	Authorizes transactions for the conduct of the official business of certain international organizations and entities.
12	2/21/2022	2/21/2022			General License 21	Authorizing Noncommercial, Personal Remittances and the Operation of Accounts	Authorizes: (1) certain transactions that are ordinarily incident and necessary to the transfer of noncommercial, personal remittances to or from the Covered Regions or for or on behalf of an individual ordinarily resident in the Covered Regions; and (2) certain transactions that are ordinarily incident and necessary to maintaining, operating, or closing an account of an individual ordinarily resident in the Covered Regions if they are: (a) of a personal nature and (b) they do not involve transfers directly or indirectly to the Covered Regions or for the benefit of persons ordinarily resident in the Covered Regions unless they are authorized by (1).
13	2/21/2022	2/21/2022			General License 22	Authorizing the Exportation of Certain Services and Software Incident to Internet-Based Communications	Authorizes certain transactions that are ordinarily incident and necessary to the exportation or reexportation, directly or indirectly, from the United States or by U.S. persons, wherever located, to persons in the Covered Regions, of services incident to the exchange of personal communications over the internet, as well as the export of software to enable such services.
14	3/11/2022				Press Release	Treasury Sanctions Kremlin Elites, Leaders, Oligarchs, and Family for Enabling Putin’s War Against Ukraine	OFAC issued a general license to authorize certain activities of nongovernmental organizations in the DNR or LNR regions of Ukraine.
15	3/11/2022	3/11/2022			General License 23	Certain Transactions in Support of Nongovernmental Organizations’ Activities	Authorizes certain transactions that are ordinarily incident and necessary to the support of nongovernmental organizations’ activities in the DNR and LNR regions of Ukraine, including activities related humanitarian projects to meet basic human needs, democracy building, education, non-commercial developments projects, and environmental and natural resource protection.
16	3/18/2022				Recent Actions Notice	Issuance of Russia-related General License 24; Publication of amended Frequently Asked Question	OFAC issued a general license authorizing certain transactions related to civil maritime services performed by individuals residing in the DNR and LNR.
17	3/18/2022	3/18/2022			General License 24	Transactions Related to the Provision of Maritime Services	Authorizes transactions related to the provision or receipt of civil maritime services performed by individuals ordinarily resident in the DNR and LNR, provided that: (1) such services are performed outside of the DNR and LNR; and (2) such services are not performed on behalf of any entity located in or organized under the laws of the DNR and LNR.
18	3/24/2022				Recent Actions Notice	Issuance of Russia-related General Licenses; Publication of amended Frequently Asked Questions	OFAC issued a general license authorizing certain journalistic activities in the DNR and LNR.
19	3/24/2022	3/24/2022			General License 25	Journalistic Activities and Establishment of News Bureaus in Certain Regions of Ukraine	Authorizes: (1) news reporting organizations that are United States persons and individuals who are United States persons regularly employed by a news reporting organization to engage in certain transactions in the DNR and LNR ordinarily incident and necessary to their journalistic activities in the DNR and LNR; and (2) news reporting organizations that are United States persons to establish and operate news bureaus in the DNR and LNR and engage in the same type of transactions as allowed in (1) to the extent those transactions are ordinarily incident and necessary to the establishment and operation of a news bureau in the DNR and LNR.
20	4/20/2022				Recent Actions Notice	Publication of Russia-related Frequently Asked Question	OFAC published a new FAQ about the obligations of operators of credit card systems have under the Russian Harmful Foreign Activities Sanctions Regulations, 31 C.F.R. part 587 (RuHSR), and the Belarus Sanctions Regulations, 31 C.F.R. part 548 (BSR), with regard to payment cards issued by sanctioned Russian financial institutions.
21	4/25/2022				Recent Actions Notice	Issuance of Ukraine-/Russia-Related General Licenses; Publication of amended Frequently Asked Questions	OFAC issued Ukraine-/Russia-related General License 13R and General License 15L. In addition, OFAC updated several Frequently Asked Questions.
22	4/25/2022	5/25/2022			General License 13R	Authorizing the Wind Down of Certain Transactions Necessary to Divest or Transfer Debt, Equity, or Other Holdings in GAZ Group	Authorizes certain divestment and transfer activities related to debt, equity, or other holdings in GAZ Group, or in entities in which GAZ Group owns (directly or indirectly) a 50 percent or greater interest, that were issued by GAZ Auto Plant, subject to certain conditions and exceptions, through May 25, 2022 at 00:01 EDT. Note that GL 13R replaces and supersedes GL 13Q, dated January 24, 2022, in its entirety.
23	4/25/2022	5/25/2022			General License 15L	Authorizing the Wind Down of Transactions Involving GAZ Group	Authorizes the wind down of transactions involving GAZ Group entities through May 25, 2022 at 00:01 EDT. Note that GL 15L replaces and supersedes GL 15K, dated January 24, 2022, in its entirety.
24	4/29/2022	5/2/2022			Recent Actions Notice	Amendment to the Ukraine-Related Sanctions Regulations and Associated Administrative List Updates	OFAC amended and reissued, in their entirety, the Ukraine-Related Sanctions Regulations, 31 C.F.R. part 589, published in abbreviated form on May 8, 2014, and renamed the regulations the Ukraine-/Russia-Related Sanctions Regulations. OFAC also revised several FAQs for the Ukraine-/Russia-Related Sanctions Regulations. The publication of the regulations triggered an automatic administrative update to a number of sanctions entries.
25
26	Venable client alerts						U.S. Responds to Putin’s Recognition of Separatist Republics in Eastern Ukraine (Feb. 22, 2022)
27							U.S. Treasury Imposes Second Round of Economic Sanctions Following Russian Takeover of Eastern Ukraine Regions (Feb. 23, 2022)
28							U.S. Sanctions Against Russia: Summary as of Tuesday, March 1, 2022 (March 2, 2022)
29							Treasury Expands Russia-Related General Licenses and Sanctions Against Russian Individuals and Entities (March 8, 2022)
30							Russia and Sanctions: What Happens Next? Compliance and Enforcement (March 14, 2022)
31							U.S. Economic Sanctions: Enforcement Strategy Against Russia Takes Shape (March 25, 2022)
32							Russia Sanctions: The U.S. Government Leans In (April 12, 2022)


1	U.S. Russia BIS Sanctions: Chronological List of Releases and Final Rules as of October 30, 2022
2				Sources:	Russia-Belarus Export Controls Resources
3					Federal Register Notices
4
5	Date Issued	Effective Date	Doc. #	Document Name	Summary

6	2/22/2022		Press Release	Commerce Imposes Sweeping Export Restrictions on Russia in Response to Further Invasion of Ukraine	BIS implemented a sweeping series of stringent export controls that will severely restrict Russia’s access to technologies and other items that it needs to sustain its aggressive military capabilities. These controls primarily target Russia’s defense, aerospace, and maritime sectors. BIS also imposed stringent controls on 49 Russian military end users, which have been added to BIS’s Entity List.
7	3/3/2022	2/24/2022	Final Rule, 87 Fed. Reg. 12226	Implementation of Sanctions Against Russia Under the Export Administration Regulations (EAR)	• New CCL-based license requirements to all ECCNs in Categories 3-9 per new § 746.8(a)(1) (Note: part 746 of the EAR deals with Embargoes and Other Special Controls). • Review policy of denial to license applications but subject to case-by-case review per § 746.8(b). • Expansion of Russia “military end use” and “military end user” control scope under § 744.21 of the EAR for Russia to apply to all items “subject to the EAR” except food and medicine designated EAR99, or ECCN 5A992.c and 5D992.c unless for Russian “government end users” and Russian state-owned enterprises (SoEs). • Two new Foreign Direct Product (FDP) Rules in § 734.9. See new § 746.8(a)(2) for license requirements and § 746.8(c)(1)-(7) for certain eligible license exceptions. • Creates a Russia FDP Rule (Russia FDP Rule) (not applicable to foreign-produced items that would be designated EAR 99). Will be new § 734.9(f) and will be subject to the license requirement described in new § 746.8(a)(2) but will be eligible for certain license exceptions described in § 746.8(c)(1)-(7). When a license application is required, such applications will be subject to a general policy of denial but will be subject to case-by-case review for certain circumstances described further in § 746.8(b). • Creates a Russia Military End Users FDP Rule (Russia-MEU FDP Rule) (more expansive than the Russia FDP Rule and does apply to EAR 99 items—requires a license if an entity with a FN 3 designation on the Entity List is a party to the transaction). Will be new § 734.9(g) and subject to the license requirement described in new § 746.8(a)(3). No license exceptions are available to overcome this license requirement, except as specified in the Entity List entry for a Footnote 3 entity on the Entity List in supplement no. 4 to part 744 of the EAR, and such items will be subject to a policy of denial for all license applications, as described in § 746.8(b). • Partner countries adopting or expressing an intent to adopt substantially similar measures are not subject to the above two FDP rules. The countries are identified in Supplement No. 3 to part 746 (Russia Exclusions List), i.e., Australia, Austria, Belgium, Bulgaria, Canada, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Japan, Latvia, Lithuania, Luxembourg, Malta, the Netherlands, New Zealand, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, and the United Kingdom. • Severe restriction on use of EAR license exceptions, including TMP, GOV, TSU, BAG, AVS, ENC, and CCD. See § 746.8(c)(1)-(7). • Applies the Entity List footnote 3 designation (see Russia-MEU FDP Rule, above) and adds some 47 entities (45 of which were transferred from the MEU List in Supplement No. 7 to part 744 and adds them to the Entity List), including the Russian Ministry of Defense, including the Armed Forces of Russia, wherever located.
8	3/4/2022		Press Release	Commerce Takes Further Actions to Target Russian Strategic Industries and Punish Enablers of Aggression	BIS issued new regulations targeting Russia’s oil refining sector with new stringent export controls and identifying 91 entities that support Russian military activities.
9	3/8/2022	3/3/2022	Final Rule, 87 Fed. Reg. 12856	Expansion of Sanctions Against the Russian Industry Sector Under the Export Administration Regulations (EAR)	Expanded the existing sanctions against the Russian industry sector by adding a new prohibition under the Export Administration Regulations (EAR) that targets the oil refinery sector in Russia.
10	3/9/2022	3/3/2022	Final Rule, 87 Fed. Reg. 13141	Further Imposition of Sanctions Against Russia with the Addition of Certain Entities to the Entity List	Amended the Export Administration Regulations (EAR) by adding 91 new entities to the Entity List under the destinations of Belize, Estonia, Kazakhstan, Latvia, Malta, Russia, Singapore, Slovakia, Spain, and United Kingdom with this final rule. These 91 entities have been determined by the U.S. Government to be acting contrary to the foreign policy or national security interests of the United States.
11	3/7/2022		Press Release	Commerce Announces Republic of Korea Exclusion Rule	BIS added South Korea to the list of countries to receive an exclusion from the license requirements required under the U.S. Russia/Belarus Sanctions rules, including the foreign direct product (FDP) rules for Russia/Belarus and Russian/Belarusian Military End Users (MEUs).
12	3/10/2022	3/4/2022	Final Rule, 87 Fed. Reg. 13627	Addition to the List of Countries Excluded from Certain License Requirements under the Export Administration Regulations (EAR)	Added South Korea to the list of countries in supplement no. 3 to part 746 that are excluded from certain § 746.8 license requirements that pertain to items destined for Russia or Belarus.
13	3/16/2022	3/11/2022	Final Rule, 87 Fed. Reg. 14785	Imposition of Sanctions on 'Luxury Goods' Destined for Russia and Belarus and for Russian and Belarusian Oligarchs and Malign Actors Under the Export Administration Regulations (EAR)	BIS implemented a new rule prohibiting access to “luxury goods.” A ‘luxury good’ refers to any item that is identified in new supplement no. 5 to part 746 of the EAR (see bottom of page 4 of the linked PDF, including wine, cigarettes, handbags, furs, silk, carpets, clothes, sportswear, jewelry, vehicles, watches, artwork, etc.) • The license requirement specific to Russia and Belarus for ‘luxury goods’ is added under new § 746.10(a)(1) of the EAR (‘Luxury goods’ license requirements for Russia and Belarus) (Embargoes and Other Special Controls). • The license requirement specific to the designated Russian and Belarusian oligarchs and malign actors for ‘luxury goods’ is added under new § 746.10(a)(2) of the EAR (Worldwide license requirement for ‘luxury goods’ for designated Russian and Belarusian oligarch and malign actors). • The new license requirements set forth in paragraphs (a)(1) and (2) apply to the ‘luxury goods’ identified in supplement no. 5 to part 746. • The difference between the two new license requirements is that while the license requirements under paragraph (a)(1) apply to exports and reexports to Russia and Belarus or transfers within Russia and Belarus, regardless of the end user, the license requirement under paragraph (a)(2) is a worldwide license requirement that applies to Russian and Belarusian oligarchs and malign actors designated by OFAC pursuant to certain specified Executive Orders. • A very limited number of license exceptions described in § 746.10(c)(1) and (2) may be used to overcome the license requirements in § 746.10(a)(1) if all of the applicable requirements of the license exceptions can be met. • No license exceptions are available to overcome the license requirements in § 746.10(a)(2). • When a license is required, applications for such items will be subject to a policy of denial.
14	3/18/2022		Press Release	Commerce Department Identifies Commercial and Private Aircraft Exported to Russia in Apparent Violation of U.S. Export Controls	BIS identified commercial and private aircraft that have flown into Russia in apparent violation of the Export Administration Regulations (EAR). In so doing, BIS is notifying the public that providing any form of service to these aircraft requires authorization.
15	3/30/2022		Press Release	Commerce Department Updates List of Aircraft Exported to Russia in Apparent Violation of U.S. Export Controls; Removes Planes Returned to Russia	BIS updated its list of aircraft that have flown into Russia in apparent violation of the Export Administration Regulations (EAR) by adding 73 new aircraft and removing 12 aircraft that have been authorized to return to owners in partner countries. In so doing, BIS is notifying the public that providing any form of service to these aircraft requires authorization.
16	3/31/2022		Press Release	Commerce Adds 120 Entities in Russia and Belarus to the Entity List, Further Limiting the Russian and Belarusian Militaries’ Access to Items That Support Aggression Against Ukraine	BIS is issuing a final rule adding 120 entities to the Entity List. Ninety-five entities are being added as military end-users under the destinations of Belarus (24 entities) and Russia (71 entities) for acquiring and attempting to acquire items subject to the Export Administration Regulations (EAR) in support of Belarus’s and Russia’s militaries. Twenty-five entities also are being added under the destination of Russia for acquiring and attempting to acquire items subject to the EAR in support of Russia’s military modernization efforts.
17	4/1/2022	4/1/2022	Final Rule, 87 Fed. Reg. 20295	Additions of Entities to the Entity List	Added 120 entities under 120 entries to the Entity List under the destinations of Belarus and Russia.
18	4/7/2022		Press Release	BIS Takes Enforcement Actions Against Three Russian Airlines Operating Aircraft in Violation of U.S. Export Controls	BIS issued orders denying the export privileges of three Russian airlines – Aeroflot, Azur Air, and UTair – due to ongoing export violations related to comprehensive export controls on Russia imposed by the Commerce Department. These three Temporary Denial Orders (TDOs) terminate the right of these airlines to participate in transactions subject to the Export Administration Regulations (EAR), including exports and reexports from the United States. The TDOs are issued for 180 days and may be renewed.
19	4/8/2022		Press Release	Commerce Announces Addition of Iceland, Liechtenstein, Norway, and Switzerland to Global Export Controls Coalition	BIS issued a rule adding Iceland, Liechtenstein, Norway, and Switzerland to the list of countries excluded from having to apply for certain licenses because they have adopted and are implementing export controls against Russia and Belarus substantially similar to those put in place by the United States.
20	4/8/2022	4/8/2022	Final Rule, 87 Fed. Reg. 21554	Additions to the List of Countries Excluded from Certain License Requirements under the Export Administration Regulations (EAR)	Added Iceland, Liechtenstein, Norway, and Switzerland to the list of countries excluded from certain U.S. export controls related to foreign-produced items.
21	4/9/2022		Press Release	Commerce Department Expands Restrictions on Exports to Russia and Belarus in Response to Ongoing Aggression in Ukraine	BIS issued a rule that expands its highly restrictive controls on the export and reexport of U.S.-origin and certain foreign-produced commodities, software, and technologies to Russia and Belarus.
22	4/8/2022	4/8/2022	Final Rule, 87 Fed. Reg. 22130	Expansion of Sanctions Against Russia and Belarus Under the Export Administration Regulations (EAR)	Expanded license requirements for Russia and Belarus under the Export Administration Regulations (EAR) to all items on the Commerce Control List (CCL), applied the new Foreign Direct Product (FDP) Rules for Russia/Belarus and to Russian/Belarusian Military End Users (MEUs) to all items on the CCL, and removed license exception eligibility for aircraft registered in, owned or controlled by, or under charter or lease by Belarus or a national of Belarus.
23	4/14/2022		Press Release	Commerce Department Identifies First Belarusian and More Russian Aircraft Exported to Belarus and Russia in Apparent Violation of U.S. Export Controls	BIS publicly identified 10 additional aircraft in likely violation of U.S. export controls, including the first seven Belarusian owned/operated commercial aircraft identified since restrictions on Belarus were tightened via regulation effective on April 8, 2022. BIS also updated the tail numbers of 32 planes already on the list to account for the planes’ purported re-registration in Russia. BIS has also authorized two planes to leave Russia and they will be removed from the list.
24	4/21/2022		Press Release	BIS Takes Enforcement Action Against Russian Cargo Airline Operating in Violation of U.S. Export Controls	BIS issued an order temporarily denying all export privileges for the Russian cargo aircraft carrier Aviastar due to ongoing violations of the comprehensive export controls imposed on Russia by the Commerce Department.
25	5/9/2022		Press Release	Commerce Increases Restrictions on U.S. Exports to Russian Industrial and Commercial Sectors	BIS released a rule building on its March 3, 2022, Russian Industry Sector Sanctions rule by expanding the scope of items subject to stringent license requirements. The items now subject to license requirements support a wide range of commercial and industrial operations, from wood products to construction machinery, and are consistent with existing restrictions on similar items put in place by the EU.
26	5/11/2022	5/9/2022	Final Rule, 87 Fed. Reg. 28758	Expansion of Sanctions Against Russian Industry Sectors Under the Export Administration Regulations (EAR)	Expanded the scope of the Russian industry sector sanctions by adding 205 6-digit Harmonized Tariff Schedule (HTS) codes and the corresponding 478 Schedule B numbers to the list of items requiring a license for the export, reexport, or transfer (in-country) to Russia in order to better align with restrictions put in place by the European Union. These items are classified as EAR99, which previously did not require a license for most exports to Russia. Also made clarifying and conforming changes to existing rules.
27	5/20/2022		Press Release	BIS Issues Temporary Denial Order Against Fifth Russian Airline and Names Second Abramovich Aircraft Violating U.S. Exports Controls	BIS issued an order denying the export privileges of a fifth Russian airline – Rossiya Airlines – due to ongoing export violations related to comprehensive export controls on Russia imposed by the Commerce Department. BIS also identified additional aircraft in likely violation of U.S. export controls, including a 787 Dreamliner owned by Russian oligarch Roman Abramovich. BIS updated the tail numbers of planes already on the list that have flown into Russia and/or Belarus in apparent violation of the EAR.
28	6/2/2022		Press Release	Commerce Adds 71 Entities to Entity List in Latest Response to Russia’s Invasion of Ukraine	BIS issued a final rule adding seventy-one entities located in Russia and Belarus to the Entity List in further response to Russia’s invasion of Ukraine. Sixty-six of the entities being added to the Entity List were determined to be "military end users" and are receiving a “footnote 3 designation.”
29	6/6/2022	6/2/2022	Final Rule, 87 Fed. Reg. 34154	Additions of Entities to the Entity List	Amended the Export Administration Regulations (EAR) by adding 71 entities under 71 entries to the Entity List.
30	6/2/2022		Press Release	Commerce Revises Russia and Belarus Export Controls, Enhances Transparency of Future Enforcement Proceedings	BIS issued a final rule that revises, corrects, and clarifies certain provisions of the Export Administration Regulations (EAR) pertaining to the sweeping export controls imposed on Russia and Belarus in response to Russia’s further invasion of Ukraine. Additionally, to enhance the transparency of BIS’s efforts to vigorously enforce export controls on Russia and Belarus, this rule amends the EAR to make future charging letters in administrative export control enforcement cases publicly available before the final disposition of such cases.
31	6/6/2022	6/2/2022	Final Rule, 87 Fed. Reg. 34131	Export Administration Regulations: Revisions to Russia and Belarus Sanctions and Related Provisions; Other Revisions, Corrections, and Clarifications	Revised, corrected, and clarified certain provisions of the EAR that pertain to controls on Russia and Belarus and related provisions: (1) made certain revisions to the EAR’s military end use and military end user controls as they apply to Russia and Belarus, as well as related modifications to the entries for entities on the Entity List that are Russian and Belarusian military end users; (2) revised restrictions that apply to items destined for certain regions in Ukraine by clarifying the categories of license applications that BIS subjects to case-by-case review; (3) clarified and corrected provisions of the EAR that pertain to luxury goods destined for Russia and Belarus and items for use in Russia’s oil refinery sector; (4) made a technical correction to an EAR provision describing items and activities subject to the EAR by adding a cross reference to the Foreign Direct Product Rules of the EAR; and (5) revised the EAR to allow export enforcement case charging letters to be made available to the public before the final administrative disposition of such cases.
32	6/6/2022		Press Release	BIS Issues Charging Letter Against Roman Abramovich for Violating U.S. Export Controls Related to Flights of his Private Jets	BIS issued an Administrative Charging Letter against Russian oligarch Roman Abramovich, alleging violations of the Export Administration Regulations (EAR) involving flights of two U.S. origin aircraft to Russia without the required export licenses from BIS.
33	6/7/2022		Press Release	U.S. Commerce Department and Canada Border Services Agency Renew Focus on Keeping Sensitive Technologies and Goods Out of Russian Hands	The Department of Commerce and the Canada Border Services Agency underlined their joint commitment to leverage their authorities and resources to detect, deter, and stop violations of export restrictions and to ensure compliance with laws and regulations. They committed to sharing information; conducting pre- and post-shipment verifications and audits; inspecting, detaining, and seizing shipments; and reducing threats through coordinated enforcement actions and investigations.
34	6/24/2022		Press Release	BIS Takes Enforcement Action Against Additional Russian Airlines and Updates List of Aircraft Operating in Likely Violation of U.S. Export Controls	BIS issued orders denying the export privileges of three Russian airlines – Nordwind Airlines, Pobeda Airlines, and S7 Airlines – due to ongoing apparent violations of the comprehensive export controls imposed on Russia by the Commerce Department. These three Temporary Denial Orders (TDOs) terminate the right of these airlines to participate in transactions subject to the Export Administration Regulations (EAR), including exports and reexports from the United States.
35	6/28/2022		Press Release	FinCEN and BIS Issue Joint Alert on Potential Russian and Belarusian Export Control Evasion Attempts	BIS issued a joint alert with FinCEN to financial institutions advising them to be vigilant against efforts by individuals or entities to evade BIS export controls implemented in connection with Russia's further invasion of Ukraine.
36	6/28/2022		Press Release	Commerce Rule Applies Powerful Restrictions Directly on Entities Seeking to Supply Russia’s Military Since Start of Invasion of Ukraine	BIS issued a new rule adding a total of 36 entities in 9 countries to the Entity List, including 6 specifically for their continued support of Russia’s military efforts since imposition of export controls in response to Russia’s invasion of Ukraine. The six entities are subject to severe restrictions on access to U.S. technologies and items for having contracted to continue to supply Russian military end users since February 24, 2022, when the current restrictions were put in place. The Department also publicly identifies two Chinese parties that have been on the Entity List since 2018 as having supported, and continued to support, Russia’s military since the imposition of new controls.
37	6/30/2022	6/28/2022	Final Rule, 87 Fed. Reg. 38920	Addition of Entities, Revision and Correction of Entries, and Removal of Entities From the Entity List	BIS amends the EAR by adding 36 entities under 41 entries to the Entity List, revising 11 existing entries, correcting one existing entry, and removing two entities and one address for a non-listed entity.
38	8/2/2022	8/2/2022	Press Release	Commerce Department Identifies First Foreign-Produced Commercial Aircraft Exported to Russia in Apparent Violation of U.S. Export Controls	BIS updated its list of aircraft that have flown into Russia or Belarus in apparent violation of the Export Administration Regulations (EAR) by adding the first 25 foreign-produced aircraft that BIS has identified as apparently violating the EAR’s de minimis threshold for U.S. components
39	8/12/2022		Press Release	Commerce Implements New Multilateral Controls on Advanced Semiconductor and Gas Turbine Engine Technologies	BIS issued an interim final rule that establishes new export controls on four technologies that meet the criteria for emerging and foundational technologies under Section 1758 of the Export Control Reform Act (ECRA) and are essential to the national security of the United States. These Section 1758 technologies support the production of advanced semiconductors and gas turbine engines.
40	8/12/2022	8/15/2022; 10/14/2022	Interim Final Rule, 87 Fed. Reg. 49979	Implementation of Certain 2021 Wassenaar Arrangement Decisions on Four Section 1758 Technologies	BIS revised the Commerce Control List (CCL), as well as corresponding parts of the EAR, to implement controls on four emerging and foundational technologies. These technologies are two substrates of ultra-wide bandgap semiconductors (Gallium Oxide and diamond), Electronic Computer Aided Design (ECAD) software specially designed for the development of integrated circuits with any Gate-All-Around Field-Effect Transistor (GAAFET) structure, and pressure gain combustion (PGC) technology for the production and development of gas turbine engine components or systems.
41	8/25/2022		Press Release	Six Months into Russian Invasion, Commerce Actions Making a Difference in Support of Ukrainian People	BIS highlighted how its restrictions on trade in commodities, software, and technologies that have supported military and civilian uses have impaired Russia's ability to repair and replace military equipment and weapons and generate revenue to support the war against Ukraine.
42	8/31/2022		Press Release	BIS Takes Enforcement Action Against PJSC LUKOIL For Violation of U.S. Export Controls	BIS issued a charging letter against PJSC LUKOIL for violating the Export Control Reform Act. The charging letter alleges PJSC LUKOIL, a Russian multinational oil and gas corporation, exported a U.S. manufactured aircraft – bearing tail number VP-CLR and manufacturer serial number 34865 – which is owned by PJSC LUKOIL, from Dubai to Russia on March 12, 2022. The DOJ announced a seizure warrant for the same aircraft.
43	9/15/2022		Press Release	Commerce Takes Further Actions to Expand and Tighten U.S. Export Controls on Russia and Belarus	BIS issued a rule applying further restrictions on Russia and Belarus. The rule: expands the scope of the Russian industry sector sanctions to add items potentially useful for Russia’s chemical and biological weapons production capabilities and items that enable advanced manufacturing across a number of industries; imposes controls on quantum computing-related hardware, software, and technology; adds Belarus to the scope of industry sector sanctions that currently apply only to Russia; expands the military end user and military-intelligence end user controls; adds additional dollar value exclusion thresholds for luxury goods; and makes twelve additional corrections and clarifications to existing controls on Russia and Belarus.
44	9/16/2022	9/15/2022	Final Rule, 87 Fed. Reg. 57068	Implementation of Additional Sanctions Against Russia and Belarus Under the Export Administration Regulations (EAR) and Refinements to Existing Controls	Expanded the existing sanctions against Russia and Belarus by imposing new export controls, including expanding the scope of the Russian industry sector sanctions to add lower-level items potentially useful for Russia's chemical and biological weapons production capabilities and items needed for advanced production and development capabilities to enable advanced manufacturing across a number of industries. Added Belarus to the scope of industry sector sanctions that currently apply solely to Russia. Expanded the military end user and military-intelligence end user controls and applied the Russian/Belarusian-Military End User Foreign Direct Product (FDP) rule to ten existing entries for six existing entities that have continued to supply Russian entities on the Entity List or are under sanction since Russia's further invasion of Ukraine. Clarified requirements related to Burma, Cambodia, the People's Republic of China, and Venezuela. Refined existing controls on Russia and Belarus by adding additional dollar value exclusion thresholds for luxury goods. Made twelve corrections and clarifications to existing controls on Russia and Belarus.
45	9/19/2022		Press Release	Commerce Identifies Iranian Cargo Airlines For Apparent Violations Of U.S Export Controls	BIS updated its list of aircraft that have flown into Russia in apparent violation of the EAR by adding the first three Iranian owned and -operated aircraft providing cargo flight services on U.S.-origin aircraft to Russia. These aircraft are operated by Mahan Air, Qeshm Fars Air, and Iran Air.
46	9/26/2022		Press Release	Commerce Identifies 4th Iranian Cargo Plane Owned by Military in Apparent Violation of U.S. Export Controls on Russia	BIS updated its list of aircraft that have flown into Russia in apparent violation of the EAR by adding a fourth Iranian-owned and -operated aircraft providing cargo flight services on U.S.-origin aircraft to Russia. Public reporting shows that an airplane owned by Saha Airlines, which itself is owned and operated by the Islamic Republic of Iran Air Force, has flown into Russia without BIS authorization since export controls were imposed on such aircraft on February 24, 2022.
47	9/30/2022		Press Release	Commerce Responds to Russia’s Attempts to Annex Parts of Ukraine	BIS issued a rule that adds 57 entities located in Russia and the Crimea region of Ukraine to the Entity List for supporting the Russian military’s assault on Ukraine (50 of these entities will also be subject to the Russia/Belarus Military End User Foreign Direct Product Rule). In addition, BIS published a new FAQ clarifying that the U.S. export controls on Russia can be applied to entities in third countries that seek to provide material support for Russia’s and Belarus’s military and industrial sectors, including to backfill technologies and other items prohibited by the United States and the 37 allies and partners that have implemented substantially similar controls.
48	10/4/2022	9/30/2022	Final Rule, 87 Fed. Reg. 60064	Additions of Entities to the Entity List	BIS amends the EAR by adding 57 entities under 57 entries to the Entity List. Of these 57 entities, 56 will be listed on the Entity List under the destination of Russia and one will be listed under the destination of the Crimea Region of Ukraine.
49	10/14/2022		Press Release	Commerce, Treasury, State Release Joint Alert Outlining the Impact of U.S. Sanctions and Export Controls Implemented in Response to Russia’s Ongoing Invasion of Ukraine on the Russian Military-Industrial Complex	OFAC, BIS, and State released an alert summarizing the sanctions and export controls imposed in response to Russia's invasion of Ukraine. The alert also discusses the strategic intent of these sanctions and export controls (degrading Russia's military capabilities and preventing Russia from projecting military force outside of Russia) and their impact thus far. The alert concludes by warning that the U.S. will continue to pursue persons who attempt to evade its sanctions and export controls.
50	10/17/2022		Press Release	Commerce Issues Temporary Denial Order Against Ural Airlines for Operating in Apparent Violation of U.S. Export Controls on Russia	Commerce issued a Temporary Denial Order terminating URAL Airlines' right to participate in transactions subject to the EAR, including exports and reexports from the U.S. Under the EAR, all international flights into Russia and some domestic Russian flights require export or reexport licenses.


1	U.S. Belarus BIS Sanctions: Chronological List of Releases and Final Rules as of October 30, 2022
2				Sources:	Russia-Belarus Export Controls Resources
3					Federal Register Notices
4
5	Date Issued	Effective Date	Doc. #	Document Name	Summary

6	3/2/2022		Press Release	Commerce Imposes Sweeping Export Restrictions on Belarus for Enabling Russia’s Further Invasion of Ukraine	BIS imposed on Belarus the export controls made effective on Russia on February 24, 2022. The rule also adds Belarus to the two new Foreign Direct Product (FDP) rules put in place on Russia last week as part of Commerce’s Russia sanctions rule, with a near total ban on exports of items to both Russian and Belarusian military end users (the “Russia/Belarus MEU FDP rule”) and adds two entities, including the Ministry of Defence of the Republic of Belarus (this listing encompasses the national armed services, including the army, navy, marine, air force, or coast guard; national guard and police; and government intelligence or reconnaissance organizations of Belarus), to the Department of Commerce’s Entity List with a footnote 3 designation. The footnote 3 designation was established under the Russia sanctions rule issued last week and ensures that the public knows that these entities are subject to the severe restrictions on receiving items, technology, and software under new the Russia-Belarus MEU FDP.
7	3/8/2022	3/2/2022	Final Rule, 87 Fed. Reg. 13048	Imposition of Sanctions Against Belarus Under the Export Administration Regulations (EAR)	Added new license requirements and review policies for Belarus to the Export Administration Regulations (EAR) to render Belarus subject to the same sanctions that were imposed on Russia under the EAR effective February 24, 2022. These new sanctions impose new Commerce Control List (CCL)-based license requirements for Belarus; revise the two foreign ‘‘direct product’’ rules (FDP rules) that are specific to Russia and Russian ‘military end users’ to make them also applicable to Belarus and Belarusian ‘military end users;’ specify a license review policy of denial applicable to all of the license requirements on Belarus that are being added in this rule, with certain limited exceptions; significantly restrict the use of EAR license exceptions; expand the existing ‘military end use’ and ‘military end user’ control scope to include Belarus for all items ‘‘subject to the EAR’’ other than food and medicine designated EAR99; and add two new Belarusian entities to the Entity List as ‘military end users.’ This rule also imposes a license requirement for nuclear nonproliferation items for exports and reexports to Belarus and removes Belarus from Country Group A:4 under the EAR. In addition, for Belarus and Russia, this rule amends the availability of License Exceptions AVS and ENC and includes clarifying guidance on the availability of CCD.
8	3/7/2022		Press Release	Commerce Announces Republic of Korea Exclusion Rule	BIS added South Korea to the list of countries to receive an exclusion from the license requirements required under the U.S. Russia/Belarus Sanctions rules, including the foreign direct product (FDP) rules for Russia/Belarus and Russian/Belarusian Military End Users (MEUs).
9	3/10/2022	3/4/2022	Final Rule, 87 Fed. Reg. 13627	Addition to the List of Countries Excluded from Certain License Requirements under the Export Administration Regulations (EAR)	Added South Korea to the list of countries in supplement no. 3 to part 746 that are excluded from certain § 746.8 license requirements that pertain to items destined for Russia or Belarus.
10	3/11/2022	3/11/2022	Final Rule, 87 Fed. Reg. 14785	Imposition of Sanctions on `Luxury Goods' Destined for Russia and Belarus and for Russian and Belarusian Oligarchs and Malign Actors Under the Export Administration Regulations (EAR)	BIS implemented a new rule prohibiting access to “luxury goods.” A ‘luxury good’ refers to any item that is identified in new supplement no. 5 to part 746 of the EAR (see bottom of page 4 of the linked PDF, including wine, cigarettes, handbags, furs, silk, carpets, clothes, sportswear, jewelry, vehicles, watches, artwork, etc.) • The license requirement specific to Russia and Belarus for ‘luxury goods’ is added under new § 746.10(a)(1) of the EAR (‘Luxury goods’ license requirements for Russia and Belarus) (Embargoes and Other Special Controls). • The license requirement specific to the designated Russian and Belarusian oligarchs and malign actors for ‘luxury goods’ is added under new § 746.10(a)(2) of the EAR (Worldwide license requirement for ‘luxury goods’ for designated Russian and Belarusian oligarch and malign actors). • The new license requirements set forth in paragraphs (a)(1) and (2) apply to the ‘luxury goods’ identified in supplement no. 5 to part 746. • The difference between the two new license requirements is that while the license requirements under paragraph (a)(1) apply to exports and reexports to Russia and Belarus or transfers within Russia and Belarus, regardless of the end user, the license requirement under paragraph (a)(2) is a worldwide license requirement that applies to Russian and Belarusian oligarchs and malign actors designated by OFAC pursuant to certain specified Executive Orders. • A very limited number of license exceptions described in § 746.10(c)(1) and (2) may be used to overcome the license requirements in § 746.10(a)(1) if all of the applicable requirements of the license exceptions can be met. • No license exceptions are available to overcome the license requirements in § 746.10(a)(2). • When a license is required, applications for such items will be subject to a policy of denial.
11	3/31/2022		Press Release	Commerce Adds 120 Entities in Russia and Belarus to the Entity List, Further Limiting the Russian and Belarusian Militaries’ Access to Items That Support Aggression Against Ukraine	BIS is issuing a final rule adding 120 entities to the Entity List. Ninety-five entities are being added as military end-users under the destinations of Belarus (24 entities) and Russia (71 entities) for acquiring and attempting to acquire items subject to the Export Administration Regulations (EAR) in support of Belarus’s and Russia’s militaries. Twenty-five entities also are being added under the destination of Russia for acquiring and attempting to acquire items subject to the EAR in support of Russia’s military modernization efforts.
12	4/1/2022	4/1/2022	Final Rule, 87 Fed. Reg. 20295	Additions of Entities to the Entity List	Added 120 entities under 120 entries to the Entity List under the destinations of Belarus and Russia.
13	4/8/2022		Press Release	Commerce Announces Addition of Iceland, Liechtenstein, Norway, and Switzerland to Global Export Controls Coalition	BIS issued a rule adding Iceland, Liechtenstein, Norway, and Switzerland to the list of countries excluded from having to apply for certain licenses because they have adopted and are implementing export controls against Russia and Belarus substantially similar to those put in place by the United States.
14	4/8/2022	4/8/2022	Final Rule, 87 Fed. Reg. 21554	Additions to the List of Countries Excluded from Certain License Requirements under the Export Administration Regulations (EAR)	Added Iceland, Liechtenstein, Norway, and Switzerland to the list of countries excluded from certain U.S. export controls related to foreign-produced items.
15	4/9/2022		Press Release	Commerce Department Expands Restrictions on Exports to Russia and Belarus in Response to Ongoing Aggression in Ukraine	BIS issued a rule that expands its highly restrictive controls on the export and reexport of U.S.-origin and certain foreign-produced commodities, software, and technologies to Russia and Belarus.
16	4/8/2022	4/8/2022	Final Rule, 87 Fed. Reg. 22130	Expansion of Sanctions Against Russia and Belarus Under the Export Administration Regulations (EAR)	Expanded license requirements for Russia and Belarus under the Export Administration Regulations (EAR) to all items on the Commerce Control List (CCL), applied the new Foreign Direct Product (FDP) Rules for Russia/Belarus and to Russian/Belarusian Military End Users (MEUs) to all items on the CCL, and removed license exception eligibility for aircraft registered in, owned or controlled by, or under charter or lease by Belarus or a national of Belarus.
17	4/14/2022		Press Release	Commerce Department Identifies First Belarusian and More Russian Aircraft Exported to Belarus and Russia in Apparent Violation of U.S. Export Controls	BIS publicly identified 10 additional aircraft in likely violation of U.S. export controls, including the first seven Belarusian owned/operated commercial aircraft identified since restrictions on Belarus were tightened via regulation effective on April 8, 2022. BIS also updated the tail numbers of 32 planes already on the list to account for the planes’ purported re-registration in Russia. BIS has also authorized two planes to leave Russia and they will be removed from the list.
18	6/2/2022		Press Release	Commerce Adds 71 Entities to Entity List in Latest Response to Russia’s Invasion of Ukraine	BIS issued a final rule adding seventy-one entities located in Russia and Belarus to the Entity List in further response to Russia’s invasion of Ukraine. Sixty-six of the entities being added to the Entity List were determined to be "military end users" and are receiving a “footnote 3 designation.”
19	6/6/2022	6/2/2022	Final Rule, 87 Fed. Reg. 34154	Additions of Entities to the Entity List	Amended the Export Administration Regulations (EAR) by adding 71 entities under 71 entries to the Entity List.
20	6/2/2022		Press Release	Commerce Revises Russia and Belarus Export Controls, Enhances Transparency of Future Enforcement Proceedings	BIS issued a final rule that revises, corrects, and clarifies certain provisions of the Export Administration Regulations (EAR) pertaining to the sweeping export controls imposed on Russia and Belarus in response to Russia’s further invasion of Ukraine. Additionally, to enhance the transparency of BIS’s efforts to vigorously enforce export controls on Russia and Belarus, this rule amends the EAR to make future charging letters in administrative export control enforcement cases publicly available before the final disposition of such cases.
21	6/6/2022	6/2/2022	Final Rule, 87 Fed. Reg. 34131	Export Administration Regulations: Revisions to Russia and Belarus Sanctions and Related Provisions; Other Revisions, Corrections, and Clarifications	Revised, corrected, and clarified certain provisions of the EAR that pertain to controls on Russia and Belarus and related provisions: (1) made certain revisions to the EAR’s military end use and military end user controls as they apply to Russia and Belarus, as well as related modifications to the entries for entities on the Entity List that are Russian and Belarusian military end users; (2) revised restrictions that apply to items destined for certain regions in Ukraine by clarifying the categories of license applications that BIS subjects to case-by-case review; (3) clarified and corrected provisions of the EAR that pertain to luxury goods destined for Russia and Belarus and items for use in Russia’s oil refinery sector; (4) made a technical correction to an EAR provision describing items and activities subject to the EAR by adding a cross reference to the Foreign Direct Product Rules of the EAR; and (5) revised the EAR to allow export enforcement case charging letters to be made available to the public before the final administrative disposition of such cases.
22	6/16/2022		Press Release	BIS Takes Enforcement Action Against Belarusian Airline Operating in Violation of U.S. Export Controls	BIS issued an order temporarily denying all export privileges for Belavia Belarusian Airlines (Belavia) due to ongoing violations of the comprehensive export controls imposed on Belarus by the Commerce Department. The flag carrier and state-owned national airline of Belarus, Belavia has been providing flight services for passengers and cargo on U.S.-origin aircraft in violation of U.S. export controls.
23	8/25/2022		Press Release	Six Months into Russian Invasion, Commerce Actions Making a Difference in Support of Ukrainian People	BIS highlighted how its restrictions on trade in commodities, software, and technologies that have supported military and civilian uses have impaired Russia's ability to repair and replace military equipment and weapons and generate revenue to support the war against Ukraine.
24	9/15/2022		Press Release	Commerce Takes Further Actions to Expand and Tighten U.S. Export Controls on Russia and Belarus	BIS issued a rule applying further restrictions on Russia and Belarus. The rule: expands the scope of the Russian industry sector sanctions to add items potentially useful for Russia’s chemical and biological weapons production capabilities and items that enable advanced manufacturing across a number of industries; imposes controls on quantum computing-related hardware, software, and technology; adds Belarus to the scope of industry sector sanctions that currently apply only to Russia; expands the military end user and military-intelligence end user controls; adds additional dollar value exclusion thresholds for luxury goods; and makes twelve additional corrections and clarifications to existing controls on Russia and Belarus.
25	9/16/2022	9/15/2022	Final Rule, 87 Fed. Reg. 57068	Implementation of Additional Sanctions Against Russia and Belarus Under the Export Administration Regulations (EAR) and Refinements to Existing Controls	Expanded the existing sanctions against Russia and Belarus by imposing new export controls, including expanding the scope of the Russian industry sector sanctions to add lower-level items potentially useful for Russia's chemical and biological weapons production capabilities and items needed for advanced production and development capabilities to enable advanced manufacturing across a number of industries. Added Belarus to the scope of industry sector sanctions that currently apply solely to Russia. Expanded the military end user and military-intelligence end user controls and applied the Russian/Belarusian-Military End User Foreign Direct Product (FDP) rule to ten existing entries for six existing entities that have continued to supply Russian entities on the Entity List or are under sanction since Russia's further invasion of Ukraine. Clarified requirements related to Burma, Cambodia, the People's Republic of China, and Venezuela. Refined existing controls on Russia and Belarus by adding additional dollar value exclusion thresholds for luxury goods. Made twelve corrections and clarifications to existing controls on Russia and Belarus.
26	9/30/2022		Press Release	Commerce Responds to Russia’s Attempts to Annex Parts of Ukraine	BIS issued a rule that adds 57 entities located in Russia and the Crimea region of Ukraine to the Entity List for supporting the Russian military’s assault on Ukraine (50 of these entities will also be subject to the Russia/Belarus Military End User Foreign Direct Product Rule). In addition, BIS published a new FAQ clarifying that the U.S. export controls on Russia can be applied to entities in third countries that seek to provide material support for Russia’s and Belarus’s military and industrial sectors, including to backfill technologies and other items prohibited by the United States and the 37 allies and partners that have implemented substantially similar controls.
27	10/4/2022	9/30/2022	Final Rule, 87 Fed. Reg. 60064	Additions of Entities to the Entity List	BIS amends the EAR by adding 57 entities under 57 entries to the Entity List. Of these 57 entities, 56 will be listed on the Entity List under the destination of Russia and one will be listed under the destination of the Crimea Region of Ukraine.


1	U.S. Russia FinCEN Releases as of October 30, 2022
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5	Date Issued	Effective Date	Doc. #	Document Name	Summary

6	3/7/2022		Press Release	FinCEN Provides Financial Institutions with Red Flags on Potential Russian Sanctions Evasion Attempts	Announces FinCEN alert providing list of red flags illustrating potential Russian attempts to avoid economic sanctions imposed by U.S., other countries.
7	3/7/2022		FIN-2022 Alert001	FinCEN Advises Increased Vigilance for Potential Russian Sanctions Evasion Attempts	Requests all financial institutions to be alert to Russian efforts to evade U.S. financial and trade restrictions on Russia. Alert provides select red flags to assist in identifying potential sanctions evasion activity and reminds financial institutions of their Bank Secrecy Act reporting obligations, including with respect to convertible virtual currency. Requests FIs to reference this alert in SAR field 2 and narrative by including "FIN-2022-RUSSIAN SANCTIONS."
8	3/16/2022		Press Release	Russia-Related Illicit Finance and Sanctions FIU Working Group Statement of Intent	Announces, with the Financial Intelligence Units (FIUs) of Australia, Canada, France, Germany, Italy, Japan, the Netherlands and U.K., the formation of the Working Group and agree to share financial intelligence to enhance sanctions enforcement.
9	3/16/2022		Press Release	FinCEN Announces Actions to Support REPO Multilateral Task Force and Ongoing U.S. Government Efforts to Combat Foreign Government Corruption	Announces FIN-2022-Alert002 and FinCEN's support for the multilateral Russian Elites, Proxies and Oligarchs (REPO) Task Force to deny REPOs access to the international financial system.
10	3/16/2022		FIN-2022 Alert002	FinCEN Alert on Real Estate, Luxury Goods, and other High-Value Assets Involving Russian Elites, Oligarchs, and their Family Members	Highlights the importance of identifying and reporting quickly suspicious transactions involving high-value assets of sanctions Russian elites, family members and proxies. Gives list of red flags. Requests that alert be referenced in SAR field 2 and include "FIN-2022-RUSSIALUXURY" in the narrative.
11	4/14/2022		Press Release	FinCEN Issues Advisory on Kleptocracy and Foreign Public Corruption	Announces advisory on kleptocracy and foreign public corruption, which highlights financial red flag indicators to assist financial institutions in preventing, detecting, and reporting suspicious transactions associated with kleptocracy and foreign public corruption.
12	6/28/2022		Press Release	FinCEN and BIS Issue Joint Alert on Potential Russian and Belarusian Export Control Evasion Attempts	Announces joint alert to financial institutions advising them to be vigilant against efforts by individuals or entities to evade BIS export controls implemented in connection with Russia's further invasion of Ukraine.
13	6/28/2022		FIN-2022 Alert003	FinCEN and the U.S. Department of Commerce’s Bureau of Industry and Security Urge Increased Vigilance for Potential Russian and Belarusian Export Control Evasion Attempts	Provides an overview of BIS’s export restrictions to date, a list of certain commodities of concern, and other information they can use and incorporate into their risk-based screening of financial transactions. Provides select transactional and behavioral red flag indicators of export control evasion, including red flags derived from recent Bank Secrecy Act reporting. Requests that alert be referenced in SAR field 2 and include "FIN-2022-RUSSIABIS" in the narrative.


1	Department of Justice Sanctions Enforcement Announcements as of October 30, 2022
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5	Date Issued	Document Name	Summary
6	3/2/2022	Attorney General Merrick B. Garland Announces Launch of Task Force KleptoCapture	A new interagency law enforcement task force, Task Force KleptoCapture, was created on March 2 “for the purpose of enforcing the sweeping sanctions, export restrictions, and economic countermeasures that the [U.S.] has imposed, along with allies and partners, in response to Russia’s unprovoked military invasion of Ukraine.” The task force will be housed in the Office of the Deputy Attorney General, and it includes “agents and analysts from numerous law enforcement agencies, including the FBI; U.S. Marshal Service, U.S. Secret Service; Department of Homeland Security–Homeland Security Investigations; IRS–Criminal Investigation; and the U.S. Postal Service.” The Task Force’s mission and authorizations are broad, giving it the tools and discretion necessary to investigate and prosecute nearly any form of sanctions violations.
7	3/3/2022	TV Producer for Russian Oligarch Charged with Violating Crimea-Related Sanctions	An indictment against Jack Hanick, a U.S. citizen working on behalf of Russian oligarch Konstantin Malofeyev, alleging violations of the U.S.’s 2014 sanctions related to Russia’s undermining of democratic processes and institutions in Ukraine was unsealed in the Southern District of New York on March 3. The American TV producer allegedly violated U.S. sanctions by working directly for and for the benefit of the Russian oligarch during the years after Malofeyev was designed as an SDN by helping Malofeyev run his Russian cable news network and acquire other news networks. The charges Hanick is facing carry a maximum penalty of 20 years imprisonment.
8	3/16/2022	U.S. Departments of Justice and Treasury Launch Multilateral Russian Oligarch Task Force	The creation of the Russian Elites, Proxies, and Oligarchs (REPO) multilateral task force was announced on March 16. This task force brings together financial regulators responsible for administering their respective governments’ sanctions regimes from the U.S., Australia, Canada, the EU, France, Germany, Italy, Japan, and the UK. Its objective is to ensure effective, coordinated implementation of the group’s collective financial sanctions relating to Russia and boost information sharing between the countries. specifically target Russian elites, proxies, and oligarchs that are enabling and facilitating Russia’s war in Ukraine. In the same announcement, the DOJ noted that the Department of Treasury’s Office of Terrorism and Financial Intelligence launched the Kleptocracy Asset Recovery Rewards Program that day, which offers reward payments for information that assists the U.S. in enforcing sanctions against the Russian government, among other things.
9	3/17/2022	Russian Elites, Proxies, and Oligarchs Task Force Ministerial Joint Statement	The names of country officials participating in the multilateral Russian Elites, Proxies, and Oligarchs Task Force (REPO Task Force) were jointly announced following the REPO Task Force’s launch meeting.
10	4/4/2022	$90 Million Yacht of Sanctioned Russian Oligarch Viktor Vekselberg Seized by Spain at Request of United States	Acting at the request of the DOJ Task Force KleptoCapture, Spanish authorities seized the 255-foot luxury yacht “M/Y Tango” owned by Russian oligarch Viktor Vekselberg. After being sanctioned in 2018, the DOJ alleges that Vekselberg continued to use shell companies to obfuscate his interest in the Tango and make U.S. dollar payments through U.S. banks for the support and maintenance of the Tango and its owners, who failed to get a license for such payments from OFAC.
11	4/5/2022	Justice Department Investigation Leads to Shutdown of Largest Online Darknet Marketplace	The online darknet market Hydra Market was shut down on April 5 by the Department of Justice and German Federal Criminal Police, who seized Hydra services and cryptocurrency wallets containing $25 million worth of bitcoin. Hydra was an online criminal marketplace that was used primarily by Russian-speaking countries to buy and sell illicit goods and services anonymously and outside the reach of law enforcement. The market was estimated to account for 80% of all darknet market-related cryptocurrency transactions. Money laundering and so-called “cash out” services that could be used to evade U.S. sanctions were popular items bought and sold on Hydra. Conspiracy charges related to drugs and money laundering were also brought against a Russian resident for his role in facilitating the operations of the darknet market.
12	4/6/2022	Russian Oligarch Charged with Violating U.S. Sanctions	Russian media oligarch Konstantin Malofeyev was charged with conspiracy to violate U.S. sanctions and violations of U.S. sanctions in the Southern District of New York according to an indictment unsealed on April 6. Malofeyev was listed as an SDN in 2014 for his connection to Russia's aggression in the Crimea region of Ukraine and his funding of Russian-backed separatists groups operating in that region. The charges against Malofeyev allege that, after being designated as an SDN, he employed an American citizen to run his cable television news network in violation of U.S. sanctions (whose indictment was announced on March 3) and that Malofeyev conspired to transfer the value of his $10 million investment in a Texas-based bank holding company out of the U.S. Both sanctions charges that Malofeyev is facing carry a maximum penalty of 20 years imprisonment.
13	4/14/2022	Russian Legislator and Two Staff Members Charged with Conspiring to Have U.S. Citizen Act as an Illegal Agent of the Russian Government in the United States	Russian Legislator Aleksandr Mikhaylovich Babakov and two of his staff members were charged with conspiring to violate U.S. sanctions, having a U.S. citizen act as an unregistered agent of Russia, and fraudulent obtaining visas to enter the United States in furtherance of a global foreign influence scheme for the Russian government. The three men, all on OFAC's SDN list, used a nonprofit organization based in Russia, the Institute for International Integration Studies, as a front for this global foreign influence campaign. On multiple occasions, the men contacted members of Congress to seek meetings and to offer free travel, including to a conference organized to benefit the purported “Prime Minister of Crimea,” Sergey Aksyonov, who has also been designated as an SDN. The men also submitted fraudulent visa applications seeking to travel to the United States under the false pretense of each traveling alone for a “vacation,” when in fact they planned to conduct unofficial meetings with U.S. politicians and advisors. The charges carry maximum penalty of up to 20 years' imprisonment.
14	5/5/2022	$300 Million Yacht of Sanctioned Russian Oligarch Suleiman Kerimov Seized by Fiji at Request of United States	Fijian law enforcement executed a seizure warrant freezing the Motor Yacht Amadea (the Amadea), a 348-foot luxury vessel owned by sanctioned Russian oligarch Suleiman Kerimov. The seizure was coordinated through the Justice Department’s Task Force KleptoCapture. OFAC designated Kerimov as part of a group of Russian oligarchs who profit from the Russian government through corruption and its malign activity around the globe, including the occupation of Crimea.
15	6/6/2022	United States Obtains Warrant for Seizure of Two Airplanes of Russian Oligarch Roman Abramovich Worth Over $400 Million	The United States has been authorized to seize a Boeing 787-8 aircraft and a Gulfstream G650ER aircraft owned and controlled by Russian oligarch Roman Abramovich, pursuant to a seizure warrant from the S.D.N.Y, which found that the airplanes are subject to seizure and forfeiture based on probable cause of violations of the Export Control Reform Act (ECRA) and the recent sanctions issued against Russia. The Boeing was flown to Russia on March 4, 2022 without a BIS license, and is now in the United Arab Emirates. The Gulfstream was flown to Russia on March 12 and 15, 2022 without a BIS license, and remains in Russia.
16	6/29/2022	Russian Elites, Proxies, and Oligarchs Task Force Joint Statement	The REPO Task Force has leveraged extensive multilateral coordination to block or freeze more than $30 billion worth of sanctioned Russians’ assets, freeze or seize sanctioned persons’ high-value goods, and heavily restrict sanctioned Russians’ access to the international financial system.
17	7/29/2022	Russian National Charged with Conspiring to Have U.S. Citizens Act as Illegal Agents of the Russian Government	Russian founder and president of the Anti-Globalization Movement of Russia Aleksandr Viktorovich Ionov was charged with orchestrating, working on behalf of the Russian government and in conjunction with the FSB, a years-long foreign malign influence campaign that used various U.S. political groups to sow discord, spread pro-Russian propaganda, and interfere in elections within the United States. Specifically, Ionov provided financial support to these groups, directed them to publish pro-Russian propaganda, coordinated and funded direct action by these groups within the United States intended to further Russian interests, and coordinated coverage of this activity in Russian media outlets. The charge carries a maximum penalty of five years in prison.
18	8/8/2022	United States Obtains Warrant for Seizure of Airplane of Sanctioned Russian Oligarch Andrei Skoch, Worth Over $90 Million	The U.S. has been authorized to seize an Airbus A319-100 owned and controlled by sanctioned Russian oligarch Andrei Skoch, pursuant to a seizure warrant from the S.D.N.Y. OFAC designated Skoch on April 6, 2018 “for being an official of the Government of the Russian Federation,” “a deputy of the Russian Federation’s State Duma,” and because of his “longstanding ties to Russian organized criminal groups, including time spent leading one such enterprise.” After Russia invaded Ukraine in 2022, OFAC designated Skoch and other members of the Duma for “support[ing] the Kremlin’s efforts to violate Ukraine’s sovereignty and territorial integrity" and identified the Airbus as blocked property in which Skoch was a beneficial owner through a series of shell companies and trusts tied to his romantic partner.
19	8/31/2022	United States Obtains Warrant for Seizure of $45 Million Airplane Owned by Russian Energy Company PJSC LUKOIL	The U.S. obtained a warrant to seize a Boeing 737-7EM aircraft owned by PJSC LUKOIL, a Russian multinational oil and gas corporation. LUKOIL owns the Boeing aircraft – bearing the tail number VP-CLR and the manufacturer serial number 34865 – which flew into and out of Russia in violation of the Department of Commerce’s sanctions against Russia. The Boeing is believed to be in Russia and worth approximately $45 million.
20	9/20/2022	U.S. Attorney General and Ukrainian Prosecutor General Met to Strengthen Joint Efforts to Hold Accountable Perpetrators of War Crimes and Other Atrocities Committed in Ukraine	In addition to discussing an MOU to facilitate appropriate cooperation, coordination, and deconfliction between each country’s respective investigations and prosecutions of war crimes and other atrocities in Ukraine, U.S. Attorney General Merrick B. Garland and Ukrainian Prosecutor General Andriy Kostin met to discuss the importance of continuing efforts to counter Russian illicit finance and sanctions evasion.
21	9/29/2022	Russian Oligarch Oleg Vladimirovich Deripaska and Associates Indicted for Sanctions Evasion and Obstruction of Justice	Russian oligarch Oleg Deripaska and two of his associates were charged with conspiring to violate and evade U.S. sanctions in an indictment unsealed on September 29. Deripaska, through the corporate entity Gracetown Inc., illegally utilized the U.S. financial system to maintain and retain three luxury properties in the U.S. and employed his associates to utilize U.S. financial institutions for his benefit in the U.S., including, for example, the sale of a music studio in California for more than $3 million. These associates were also involved in a scheme for the mother of Deripaska's children to enter the U.S. for the purpose of giving birth on a tourist visa. One of the associates and the mother were charged with making false statements to federal agents in connection with this scheme. Lastly, one of the associates was charged with destroying records after receiving a grand jury subpoena for those records.
22	9/30/2022	Readout of Russian Elites, Proxies, and Oligarchs (REPO) Task Force Deputies Meeting	The REPO Task Force deputies met to accelerate oligarch asset forfeiture efforts. They discussed legislative proposals in the U.S., including proposals to forfeit oligarch assets on an expedited timeline, to forfeit property used to facilitate sanctions evasion, to expand the ability to enforce foreign forfeiture judgments in U.S. courts, and to include sanctions and export control violations among the crimes that fall within the definition of racketeering.
23	10/11/2022	U.K. Businessman Graham Bonham-Carter Indicted for Sanctions Evasion Benefitting Russian Oligarch Oleg Vladimirovich Deripaska	U.K. businessman Graham Bonham-Carter was arrested for conspiracy to violate U.S. sanctions imposed on Russian oligarch Oleg Deripaska and wire fraud in connection with funding U.S. properties purchased by Deripaska and efforts to expatriate Deripaska’s artwork in the United States through misrepresentations. Bonham-Carter has worked for entities controlled by Deripaska since 2003. After Deripaska was designated in 2018, Bonham-Carter continued to manage real estate in the U.S. for Deripaska's benefit. Bonham-Carter also attempted to ship artwork purchased by Deripaska from an auction house in New York City to London by denying that Deripaska owned the artwork and denying that Deripaska would pay the shipping fees.
24	10/17/2022	Intertech Trading Corp. Sentenced to Pay $140,000 on 14 Felony Counts of Failure to File Export Information on Shipments of Lab Equipment to Russia and Ukraine	Intertech Trading Corporation, a New Hampshire lab equipment distributor, pled guilty to 14 counts of failure to file export information on shipments to Russia and Ukraine. Intertech did not accurately describe the equipment or report its value.
25	10/19/2022	Justice Department Announces Charges and Arrests in Two Cases Involving Export Violation Schemes to Aid Russian Military	Five Russian nationals and two Venezuelan oil brokers were charged with obtaining military technology from U.S. companies such as advanced semiconductors and microprocessors, smuggling millions of barrels of oil, and laundering tens of millions of dollars for Russian industrialists, sanctioned entities, and the world's largest energy conglomerate. In addition, three individuals and two companies were charged with attempting to smuggle a jig grinder (a dual-use, export-controlled item) manufactured in Connecticut to Russia.


1	U.S. Belarus OFAC Sanctions: Chronological List of Releases, Directives, and General Licenses as of October 30, 2022
2						Sources:	OFAC Recent Actions
3							Belarus Sanctions
4						Venable Client Alerts at bottom of chart
5	Date Issued	Effective Date	Expiration Date (GLs)	Update Date	Doc. #	Document Name	Summary

6	2/24/2022				Press Release	U.S. Treasury Targets Belarusian Support for Russian Invasion of Ukraine	OFAC sanctioned two significant state-owned banks that are among the most important banks in Belarus: Belarussian Bank of Development and Reconstruction Belinvestbank Joint Stock Company (Belinvestbank) and Bank Dabrabyt Joint-Stock Company (Bank Dabrabyt). OFAC also sanctioned entities and individuals linked to the Belarusian defense and security industries.
7	2/24/2022	2/24/2022			General License 6	Official Business of the United States Government	Authorizes transactions for the conduct of the official business of the U.S. government.
8	2/24/2022	2/24/2022			General License 7	Official Business of Certain International Organizations and Entities	Authorizes transactions related to the official business of certain international organizations and other entities.
9	3/15/2022				Press Release	Treasury Sanctions Russians Connected to Gross Human Rights Violations and Corrupt Leader of Belarus	OFAC re-designated President Alyaksandr Lukashenka and designated his wife, Halina Radzivonawna Lukashenka, for being a senior-level official and the family member of a senior-level official, respectively, who are responsible for or have engaged in public corruption related to Belarus.
10	7/11/2022				Recent Actions Notice	Iran-related Designations; Belarus Designation Update	OFAC updated the designation of the Belarusian Oil Trade House.
11	9/30/2022				Press Release	Treasury Imposes Swift and Severe Costs on Russia for Putin’s Purported Annexation of Regions of Ukraine	In response to Russia's sham referenda, purported annexation, and occupation of the Kherson, Zaporizhzhya, Donetsk, and Luhansk regions of Ukraine, OFAC designated 14 persons in Russia’s military-industrial complex, including a Belarusian state-owned textile and fiber manufacturer that exports to Russia, Open Joint Stock Company Svetlogorsk Khimvolokno (Sohim).
12	9/30/2022				Recent Actions Notice	Russia-related Designations and Designations Updates; Publication of Russia-related Frequently Asked Question	OFAC published a Russia-related FAQ (1091) and updated the SDN List.
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16	Venable client alerts						U.S. Responds to Putin’s Recognition of Separatist Republics in Eastern Ukraine (Feb. 22, 2022)
17							U.S. Treasury Imposes Second Round of Economic Sanctions Following Russian Takeover of Eastern Ukraine Regions (Feb. 23, 2022)
18							U.S. Sanctions Against Russia: Summary as of Tuesday, March 1, 2022 (March 2, 2022)
19							Treasury Expands Russia-Related General Licenses and Sanctions Against Russian Individuals and Entities (March 8, 2022)
20							Russia and Sanctions: What Happens Next? Compliance and Enforcement (March 14, 2022)
21							U.S. Economic Sanctions: Enforcement Strategy Against Russia Takes Shape (March 25, 2022)
22							Russia Sanctions: The U.S. Government Leans In (April 12, 2022)