Enhanced Global Russian Sanctions And Export Controls To Counter Circumvention

On May 19, in response to Russia's ongoing invasion of Ukraine, the United States, in coordination with allies and partners, announced new sanctions restrictions and export controls targeting Russia's evasion networks, critical technology-acquisition channels, energy extraction capabilities and financial conduits. A key new reporting obligation has also been created for holders of property of the Russian Central Bank and Ministry of Finance.

These measures align with expected forthcoming restrictions imposed by the United Kingdom and an anticipated 11th tranche of EU sanctions and underscore a pronounced enforcement focus on sanctions evasion through third countries in Europe, Central Asia and the Middle East.