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On Feb. 24, 2022, President Biden announced significant new export controls and sanctions against Russia in response to the Russian invasion of Ukraine. The latest sanctions package comes on the heels of a first wave of U.S. sanctions announced over the past several days, and combines financial restrictions implemented by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and significant new export controls implemented by the U.S. Department of Commerce’s Bureau of Industry and Security (BIS).

Second Wave of Sanctions

In his speech on Feb. 24, 2022, President Biden announced a second wave of sanctions designed to seriously impact Russia’s financial sector and access to capital. These measures follow an initial sanctions package announced on Feb. 22, 2022, which was targeted at the so-called Donetsk People’s Republic and the Luhansk People’s Republic (collectively, the Covered Regions) as well as the sanctions relating to Nord Stream 2 issued Feb. 23, 2022. In conjunction with President Biden’s announcement, OFAC implemented the following additional sanctions measures:

  • Cut off Sberbank, Russia’s largest financial institution, from the U.S. financial system by prohibiting correspondent and payable-through accounts);
  • Designated several other Russian financial institutions as Specially Designated Nationals (SDNs) – including Russia’s second-largest financial institution, VTB Bank – rendering their U.S. assets blocked and prohibiting U.S. persons from engaging in virtually all dealings with them;
  • Restricted U.S. person dealings in new debt and equity of over a dozen significant Russian enterprises and entities; and
  • Designated several Russian and Belarusian individuals and entities as SDNs (which, as noted above, freezes their assets and prevents virtually all U.S. person dealings).

Click here to read the full GT Alert.

Tags: Cyril T. Brennan, Export Controls & Economic Sanctions, Francisco J. Vélez, Government Law & Policy, GT Alert, GT Insight, GT Washington D.C., international trade, Kara M. Bombach, Sonali Dohale
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Photo of Kara M. Bombach Kara M. Bombach

Kara Bombach assists companies and organizations to lawfully export goods, technology and services around the globe. She places emphasis on helping clients achieve practical, workable solutions to complex regulatory situations arising under anti-corruption and anti-bribery measures (U.S. Foreign Corrupt Practices Act (FCPA) and

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Kara Bombach assists companies and organizations to lawfully export goods, technology and services around the globe. She places emphasis on helping clients achieve practical, workable solutions to complex regulatory situations arising under anti-corruption and anti-bribery measures (U.S. Foreign Corrupt Practices Act (FCPA) and OECD Convention), export control laws (EAR and ITAR), anti-boycott laws, and special sanctions (embargoes) maintained by the U.S. government (OFAC and other agencies) against various countries (including Iran, Cuba and Russia), entities and individuals. In cases of foreign investment in the United States, Kara advises on the Exon-Florio provisions relating to U.S. national security concerns. She represents companies before the Committee on Foreign Investment in the United States (CFIUS), and also assists clients in mitigating foreign ownership, control or influence (FOCI) as may be required by CFIUS or U.S. national industrial security regulations.

Kara regularly represents clients in matters before U.S. government agencies, including the U.S. Departments of Commerce, State, Treasury and Defense. Kara has significant experience representing individuals and entities before OFAC in delisting matters and challenges to OFAC sanctions designations.

She advises national and multi-national companies (including Fortune® 5) on best practices in the development and delivery of compliance policies and procedures, training, and risk assessments, as well as executing cross-border export, sanctions and anti-corruption due diligence in mergers and acquisitions, targeted internal risk assessments, and compliance investigations.

Kara also counsels international not-for-profit and relief/aid organizations on best practices in economic sanctions, trade, and anti-corruption compliance issues that arise in their global operations, frequently in challenging and austere environments. She has provided legal services to organizations such as Save the Children (US), ONE Campaign, Mercy Corps, the International Committee of the Red Cross, Not on Our Watch/The Sentry, and The Enough Project.

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Photo of Cyril T. Brennan Cyril T. Brennan

Cyril (Cy) Brennan focuses his practice on international trade regulation and compliance, with an emphasis on U.S. export controls and economic sanctions. Cy handles matters regarding the International Traffic in Arms Regulations (ITAR), the Export Administration Regulations (EAR), U.S. sanctions programs administered by…

Cyril (Cy) Brennan focuses his practice on international trade regulation and compliance, with an emphasis on U.S. export controls and economic sanctions. Cy handles matters regarding the International Traffic in Arms Regulations (ITAR), the Export Administration Regulations (EAR), U.S. sanctions programs administered by the Treasury Department’s Office of Foreign Assets Control (OFAC) and the Department of Commerce’s anti-boycott regulations. In addition, he represents clients before the Committee on Foreign Investment in the United States (CFIUS), and advises clients on the Foreign Corrupt Practices Act (FCPA), the foreign direct investment reporting requirements of the Bureau of Economic Analysis (BEA), and other trade and investment-related regulations in the context of mergers and acquisitions.

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Photo of Sonali Dohale Sonali Dohale

Sonali Dohale assists companies engaged in international business navigate U.S. international trade laws and regulations. She counsels clients on a range of economic sanctions and export controls issues, including those arising under sanctions programs administered by the U.S. Department of the Treasury’s Office…

Sonali Dohale assists companies engaged in international business navigate U.S. international trade laws and regulations. She counsels clients on a range of economic sanctions and export controls issues, including those arising under sanctions programs administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), the International Traffic in Arms Regulations (ITAR), and the Export Administration Regulations (EAR). Sonali also represents companies engaged in cross-border mergers and acquisitions before the Committee on Foreign Investment in the United States (CFIUS). Her practice also involves assisting companies with internal investigations and compliance programs under various anti-corruption regimes (including the U.S. Foreign Corrupt Practices Act (FCPA) and World Bank’s Integrity Compliance Guidelines).

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Photo of Francisco J. Vélez ‡ Francisco J. Vélez ‡

Francisco J. Vélez focuses his practice on international trade regulation with an emphasis on U.S. export controls and economic sanctions. He counsels clients on a range of economic sanctions and export controls issues, including those arising under sanctions programs administered by the U.S.

Francisco J. Vélez focuses his practice on international trade regulation with an emphasis on U.S. export controls and economic sanctions. He counsels clients on a range of economic sanctions and export controls issues, including those arising under sanctions programs administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), the International Traffic in Arms Regulations (ITAR), and the Export Administration Regulations (EAR).

‡ Admitted to practice in Florida. Practice in District of Columbia limited to federal courts and agencies.

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