The U.S. announced a new set of sweeping Russia-related export controls and sanctions this week to mark the two-year anniversary of Moscow’s invasion of Ukraine and to respond to Russian opposition figure Alexei Navalny's death in prison. The measures include nearly 100 additions to the Commerce Department’s Entity List and more than 500 sanctions designations by the Treasury and State departments in what the U.S. said is its largest single tranche of designations since Russia began the war in 2022.
President Joe Biden on Dec. 22 signed an executive order that expands U.S. sanctions authorities against foreign financial institutions facilitating “significant transitions” involving Russia’s military industrial base. The order authorizes new sanctions against banks facilitating those transactions on behalf of certain already-designated parties and it allows the U.S. to sanction banks facilitating sales of certain “critical items” to Russia, the White House said in a fact sheet.
The Bureau of Industry and Security added 13 Chinese technology companies to its Unverified List, it said in a final rule effective Dec. 19. BIS said it hasn’t been able to verify the “legitimacy and reliability” of the entities through end-use checks, including their ability to responsibly receive controlled U.S. exports. All export license exceptions involving those parties will be suspended, and exporters must file certain Electronic Export Information and obtain a statement from any party listed on the UVL before proceeding with certain exports.
The Bureau of Industry and Security added 42 parties to the Entity List for helping to illegally supply parts and drones to Russia’s military industrial base, performing contracts for Russian government entities or for doing business with sanctioned companies. The companies and people added to the list are located in China, Cyprus, Germany, Kazakhstan, the Netherlands, Russia and the United Arab Emirates.
In its largest-ever civil sanctions penalty, the Treasury Department on Nov. 21 announced a $968 mllion settlement with Binance, the world’s biggest cryptocurrency exchange, for allegedly violating multiple U.S. sanctions programs. Treasury said Binance senior management tried to “project an image of compliance” but in reality allowed people that were either subject to sanctions or located in sanctioned jurisdictions to use its platform, and management also took steps to “undermine” the company’s own compliance procedures. Binance didn’t voluntarily disclose the violations, Treasury said, calling the case “egregious.”
The Bureau of Industry and Security added four entities to the Entity List for either illegally supplying parts to Russia’s defense industrial base or helping Venezuela illegally acquire U.S. aircraft parts. The four companies, some of which have locations in multiple countries, are located in Costa Rica, Ecuador, India, Panama, Spain, Russia and Venezuela. Effective Nov. 17, the companies are subject to license requirements for all items subject to the Export Administration Regulations, and licenses will be reviewed under either a policy of denial or presumption of denial.
The Bureau of Industry and Security added 13 entities from Russia and Uzbekistan to its Entity List for helping Russia procure and develop unmanned drones. The entities, listed in a final rule effective Nov. 2, are subject to license requirements for all items subject to the Export Administration Regulations, and licenses will be reviewed under a policy of denial, apart from certain food and medicine. The entities are also subject to licensing restrictions under the BIS Russia/Belarus-Military End User Foreign Direct Product rule.
The Bureau of Industry and Security on Oct. 27 announced an immediate 90-day suspension of new export licenses for certain firearms, components and ammunition while it reviews its firearms policies to determine whether any permanent changes are “warranted.” During the next 90 days, the agency said it will not issue any new licenses for those exports to non-government end users worldwide, apart from Ukraine, Israel or a nation listed in Country Group A:1.
The Bureau of Industry and Security officially released the texts of two rules to update its Oct. 7, 2022, China chip controls, including an interim final rule that will update controls on certain semiconductor manufacturing items and another interim final rule that will update restrictions on certain advanced computing items, supercomputer and semiconductor end-uses and make other updates and corrections.
The Bureau of Industry and Security today will release a range of updates to its 2022 China chip rule, including new restrictions on several dozen additional chip tools and related items, updated export control parameters for chips used in artificial intelligence applications, a novel notification requirement for certain “gray-zone” chips that fall just below that updated threshold, a new license requirement for chip exports to companies headquartered in nations subject to a U.S. arms embargo and more. BIS also added 13 Chinese companies to the Entity List, effective Oct. 17, for developing advanced chips in ways BIS said are contrary to U.S. national security.