OFAC, BIS Release New Russia Sanctions And Export Control Alert

Illustrating the trend of coordinated sanctions actions taken by the Treasury and Commerce Departments, last week the Office of Foreign Assets Control ("OFAC") worked in tandem with the Commerce Department Bureau of Industry and Security to publish an Alert entitled, "OFAC-BIS Alert: Impact of Sanctions and Export Controls on Russia's Military-Industrial Complex," which discusses the impact of sanctions and export controls on Russia's defense capabilities.

The Alert notes that Russia has attempted to evade the impacts of the sanctions through a range of techniques, including using front companies and fraudulent end-user licenses. OFAC and its sister agencies have addressed such evasion by imposing sanctions on deceptive or structured transactions designed to circumvent US sanctions, and by providing financial institutions with a list of transactional and behavioral red flags that may assist with identifying suspicious transactions relating to possible export