On Friday, February 23, the U.S. government announced additional sanctions and export controls on Russia to commemorate the two-year anniversary of Russia’s invasion of Ukraine and in response to Russian anti-corruption activist Aleksey Navalny’s death.

The Bureau of Industry and Security (BIS) announced that it has added 93 entities (under 95 entity listings) to the Entity List for a variety of reasons related to support of Russia’s defense industry and war effort.  Sixty-three (63) of the entities are in Russia, but sixteen (16) are in Turkey, eight (8) are in China, four (4) are in the UAE, two (2) are in the Kyrgyz Republic, and one each are in Egypt and South Korea.  Fifty of these entities are subject to designation as Russian military end users, which subjects to them to the Russia military end user (MEU) controls.

BIS also announced the addition of five (5) HTS classifications to the Common High Priority Items List of items identified by the U.S., EU, Japan, and the UK as priorities for Russian procurement for weapons programs.  Some of these items are subject to control under Export Control Classification Numbers, while others are on sanctions lists in the supplements to Part 746 of the Export Administration Regulations. 

The Office of Foreign Assets Control (OFAC) announced the addition of almost 300 individuals and entities to the Specially Designated Nationals (SDN) List and four new General Licenses.  The additions to the SDN List include Russian defense industry and financial entities, as well as sanctions evaders in Europe, Asia, and the Middle East.

The State Department announced the imposition of sanctions on more than 250 entities and individuals.  The additions include entities and individuals engaged in sanctions evasion and circumvention, entities and individuals involved in Russia’s energy, metals, and mining industries, and three individuals in connection with the death of Mr. Navalny. 

Clients should review any projects involving Russia to ensure they are not impacted and conduct revised screening to ensure even previously permissible transactions are not impacted by the new sanctions.  

Contact Sean Murray, Bryan Brown, or Chuck Ballard with questions.