White HouseToday, President Trump officially signed H.R. 3364, the “Countering America’s Adversaries Through Sanctions Act” (CAATSA) into law. CAATSA originated as a bill which was focused on only Iran. However, partially in response to Russian cyber-interference with the 2016 election, the Senate expanded CAATSA to impose additional sanctions against Russia and also codify into law various sanctions imposed by the Obama Administration in the form of Executive Orders. The House of Representatives then approved these additions and added further sanctions against North Korea. Eventually, the House and Senate approved the final version of CAATSA by a margin of 419-3 and 98-2, respectively. For additional detail on CAATSA’s legislative history, please see our previous alerts here, here and here.

Continue Reading President Signs Russian, Iran and North Korea Sanctions Legislation into Law

White HouseLast night, Thursday, July 27, the U.S. Senate voted to pass the “Countering America’s Adversaries Through Sanctions Act” by a vote of 98-2. The House of Representatives passed the bill on Tuesday after adding in new sanctions against North Korea. Among other things, the legislation would impose additional sanctions against Russia and restrict President Trump’s ability to withdraw or relax previous Russian sanctions imposed by the Obama Administration.  To learn more about the bill, please see our July 26th post. The Senate created the bill back in June, where it also passed 98-2, before sending it to the House. Despite reports that the addition of North Korea would result in a delay from the Senate, the Senate passed it just over 48 hours after the House.

Continue Reading Senate Sends Russian Sanctions Bill to the President

Congress ChamberYesterday, July 25th, the U.S. House of Representatives passed the “Countering America’s Adversaries Through Sanctions Act” by a vote of 419-3. The bill originated as an act in the Senate which was focused on Iran. In response to Russian meddling in the U.S. election, the Senate expanded that bill to include additional sanctions against Russia, codify various Russia-Ukraine sanctions promulgated by the Obama Administration into law and add procedural provisions to delay or prevent any efforts by the Trump Administration to relax those codified Obama Administration sanctions. The Senate passed their revised version of this legislation last month by a vote of 98-2. For more information on the Senate’s earlier approval, please see our post on June 16th.

Continue Reading Congress Passes Russian Sanctions Bill with New Sanctions on Russia, Iran and North Korea

Treasury DepartmentToday, the Trump Administration announced that the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has updated the U.S. sanctions list of designated individuals and entities involved in the Ukrainian conflict. The announcement was made while Ukrainian President Petro Poroshenko was meeting with President Trump and other officials at the White House.

This action designates 38 individuals and entities under Ukraine-related authorities, thereby blocking access to property these individuals may have in the United States and prohibiting all transactions by U.S. persons involving these individuals.


Continue Reading OFAC Updates List of Blocked Individuals and Entities Connected to Ukraine Conflict

globe AsiaOn Thursday, June 15, 2017, by a vote of 98-2, the U.S. Senate overwhelmingly passed a bill that would potentially impose additional sanctions against Russia and give Congress the power to delay and/or prevent any action by President Trump to lift or relax sanctions against Russia. Tentatively titled the “Countering Russian Influence in Europe and Eurasia Act of 2017” (“CRIEEA”), the bill must now proceed to the U.S. House of Representatives for further deliberation and approval.

Continue Reading Senate Passes Potential Russian Sanctions Bill

Shipping containersOn March 28, 2017, Petitioners Charter Steel, Gerdau Ameristeel US Inc., Keystone Consolidated Industries, Inc., and Nucor Corporation filed a petition for the imposition of antidumping duties and countervailing duties on imports of Carbon and Alloy Steel Wire Rod from Belarus, Italy, the Republic of Korea, the Russian Federation, the Republic of South Africa, Spain, Turkey, Ukraine, United Arab Emirates, and the United Kingdom.

SCOPE OF THE INVESTIGATION

The merchandise covered by these investigations are certain hot-rolled products of carbon steel and alloy steel, in coils, of approximately round cross section, less than 19.00 mm in actual solid cross-sectional diameter. Specifically excluded are steel products possessing the above-noted physical characteristics and meeting the Harmonized Tariff Schedule of the United States (HTSUS) definitions for (a) stainless steel; (b) tool steel; (c) high-nickel steel; (d) ball bearing steel; or (e) concrete reinforcing bars and rods. Also excluded are free cutting steel (also known as free machining steel) products (i.e., products that contain by weight one or more of the following elements: 0.1 percent or more of lead, 0.05 percent or more of bismuth, 0.08 percent or more of sulfur, more than 0.04 percent of phosphorous, more than 0.05 percent of selenium, or more than 0.01 percent of tellurium). All products meeting the physical description of subject merchandise that are not specifically excluded are included in this scope.


Continue Reading Petition Summary: Carbon and Alloy Steel Wire Rod from Belarus, Italy, Korea, Russia, South Africa, Spain, Turkey, Ukraine, the UAE and the UK

Treasury DepartmentAs previously reported here, former President Obama in December 2016 issued an amendment to Executive Order (“EO”) 13694, which imposed sanctions on the Russian Federal Security Service (a.k.a Federalnaya Sluzhba Bezopasnosti and/or FSB) (“FSB”), other Russian entities and officers of those entities. The Department of Treasury’s Office of Foreign Assets Control (“OFAC”) also placed FSB and those entities and individuals on its list of Specially Designated Nationals and Blocked Persons (the “SDN List”).  These sanctions prohibited persons subject to US jurisdiction from transacting business with the FSB and the other entities and individuals named in EO 13694 and the SDN List designations.

Continue Reading OFAC Issues General License Authorizing Limited Interactions With Russia’s FSB

shipping containersFollowing the recent release of a joint analysis report by the Federal Bureau of Investigation (FBI) and department of Homeland Security (DHS) on Russian Malicious Cyber Activity and sanctions issued by the Obama Administration on December 29, 2016 (as previously reported here), the Department of Commerce’s Bureau of Industry and Security (BIS) has amended the Export Administration Regulations (EAR) by adding five (5) Russian entities to the Entity List.  The entities identified below have been determined to have been involved in activities contrary to the national security or foreign policy interests of the United States:

Continue Reading Commerce Targets Russian Hackers with Additions to Entity List

Yesterday, President Obama issued an amendment to Executive Order 13694 related to malicious cyber activities which imposed sanctions on two Russian intelligence agencies (the Federal Security Service and the Main Intelligence Directorate), four individual intelligence agency officers and three Russian vendors that provided cyber support to one of the sanctioned agencies. In an official statement, President Obama explained that the amendment was a response to “the Russian government’s aggressive harassment of U.S. officials and cyber operations aimed at the U.S. election.” The amendment also authorized the Secretary of the Treasury to sanction any additional individuals or entities determined to be engaged in “tampering with, altering, or causing a misappropriation of information with the purpose or effect of interfering with or undermining election processes or institutions.”  The nine individuals and entities named in the E.O. 13694 amendment are now listed on the list of Specially Designated Nationals and Blocked Persons (the “SDN list”) maintained by the Department of Treasury’s Office of Foreign Assets Control (“OFAC”).  This places a freeze on any property within the U.S. belonging to those individuals or entities and also prohibits persons subject to U.S. jurisdiction from engaging in trade with the sanctioned individuals and entities.  Shortly thereafter, OFAC exercised its authority under a separate section of E.O. 13694 and added two Russian cyber criminals to the SDN list along with the nine individuals and entities named by President Obama (list found here).

Continue Reading President Obama and OFAC Issue New Sanctions in Response to Russian Involvement in Elections

shipping containersOn December 20, 2016, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued its latest round of Russian sanctions as part of the ongoing U.S. response to Russia’s 2014 annexation of Ukraine’s Crimean peninsula and its subsequent escalation of conflict in the region. The new sanctions target seven individuals, eight entities, and two vessels. OFAC also added an additional 26 subsidiaries of Russian banks already subject to sanctions to the U.S. Sectoral Sanctions List. The new sanctions come one day after the European Union extended its sanctions against Russia for an additional six months.
Continue Reading Treasury Department Issues New Sanctions Against Russia