The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:

  • 17 Jan 2023 (Russia - Countermeasures): Certain EU persons are banned from entering Russia.
  • 17 Jan 2023 (Russia - Countermeasures): Certain Russian companies are allowed not to take into account the votes of "unfriendly" shareholders and their board nominees when adopting corporate resolutions.
  • 17 Jan 2023 (OFAC): OFAC amended and reissued three Russia-related General Licenses (GL), namely:
    • Russia-related GL 6C, "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," which replaces and supersedes GL 6B.
    • Russia-related GL 54A, "Authorizing Certain Transactions Involving VEON Ltd. or VEON Holdings B.V. Prohibited by Executive Order 14071," which replaces and supersedes GL 54.
    • Russia-related GL 28B, "Authorizing the Wind Down and Rejection of Certain Transactions Involving Public Joint Stock Company Transkapitalbank and Afghanistan," which replaces and supersedes GL 28A.
  • 17 Jan 2023 (OFAC): OFAC amended four existing FAQs: two FAQs (FAQs 1054 and 1055) that provide guidance regarding the term "new investment" for purposes of Executive Orders (E.O.s) 14066, 14068, and 14071 (collectively, the "New Investment E.O.s"); one FAQ (FAQ 1059) that modifies guidance regarding the bans on specified categories of services (i.e., accounting, trust and corporate formation, and management consulting services, and quantum computing services) that were previously issued pursuant to E.O. 14071; and one FAQ (FAQ 982) which provides guidance regarding the treatment of securities of blocked banks and investment in funds containing such securities.
  • 15 Jan 2023 (Ukraine): Content provided in collaboration with Sayenko Kharenko. Under the Decree of the President of Ukraine "On Decision of the National Security and Defence Council of Ukraine of 15 January 2023 "On Application of and Amending Personal Special Economic Sanctions and Other Restrictive Measures (Sanctions)" No. 13/2023, dated 15 January 2023, different sanctions were applied to 198 individuals being journalists, bloggers, sociologists, singers and other cultural figures.
  • 12 Jan 2023 (Ukraine): Content provided in collaboration with Sayenko Kharenko. Under the Decree of the President of Ukraine "On Decision of the National Security and Defence Council of Ukraine of 12 January 2023 "On Application of and Amending Personal Special Economic Sanctions and Other Restrictive Measures (Sanctions)" No. 14/2023, dated 12 January 2023, different sanctions were applied to SIA Royal Pay Europe.
  • 12 Jan 2023 (Russia - Countermeasures): "Personal sanctions" are imposed on 36 UK citizens.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.