25 March, 2022
In the past several weeks, the United States (“US”), like many other countries around the globe, began issuing and implementing a series of sweeping economic sanctions, export controls, and trade restrictions in response to events in Ukraine taken by Russia. Responsive actions taken to date by the US are numerous, have developed quickly, and continue to evolve on a daily basis. Below, we summarize some of the main actions taken by the US through 18 March 2022 that impact trade, certain financial institutions, government officials, and other individuals with ties to the region and the Russian government.
This summary is not intended to be exhaustive and excludes the actions taken by other nations. Additional alerts may be issued as events evolve.
Several Executive Orders (EO), both past and recent, underpin various export control actions, including:
Additionally, on 26 February 2022, the Biden Administration announced that the US would join several other nations in removing Russian banks from the Society for Worldwide Interbank Financial Communications, the global messaging system used by over 11,000 banks worldwide to facilitate international payments. The stated goal, as released by the White House, is to “ensure that these banks are disconnected from the international financial sytem and harm their ability to operate globally.”
The US Department of Treasury’s Office of Foreign Assets Control (“OFAC”) has also recently issued multiple measures affecting the Government of Russia and/or specific entities named in these actions. These include:
Compliance with these sanctions is required by 12:01 a.m. US Eastern Time on 26 March 2022.
Also pursuant to the directives of EO 14065, OFAC blocked property of certain persons and prohibited certain transactions related to continued Russian efforts to undermine Ukraine, including:
On 24 February 2022, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule with immediate effect to restrict exports to Russia and certain regions of Ukraine controlled by Russia. Such restricted exports included certain US- and foreign-produced items. The restrictions set forth in the final rule included:
On 2 March 2022, the BIS issued another final rule essentially placing the same export restrictions on Belarus, effective 2 March 2022.
Additionally, on 3 March 2022, the BIS announced that it would amend the EAR, effective 3 March 2022, to further restrict exports to Russia by generally prohibiting the export of machinery and equipment used for refining oil.
Finally, on 11 March 2022, the BIS published further amendments to the EAR, effective 11 March 2022, to implement the restrictions on the export of “luxury goods” to Russia and Belarus pursuant to EO 14068.
Deloitte’s Global Trade Advisory specialists are part of a global network of professionals who can provide specialized assistance to companies in global trade matters. Our professionals can help companies seeking to manage the impacts and potential impacts of the developments described above.