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ARTICLE · 18 AUGUST 2022

Export Control Reform Act: New Tool In Enforcing Russian Sanctions

Buchanan Ingersoll & Rooney
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The U.S. government continues to expand its tools for seizing Russian-controlled assets following the Russian invasion of Ukraine. In the past two months, the U.S. Department of Justice (DOJ) has obtained a ...

United StatesInternational Law
Daniel B. Pickard
Daniel B. Pickard
Karima Tawfik Thompson
Karima Tawfik Thompson
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The U.S. government continues to expand its tools for seizing Russian-controlled assets following the Russian invasion of Ukraine. In the past two months, the U.S. Department of Justice (DOJ) has obtained a seizure warrant for high-profile airplane assets through the Export Control Reform Act of 2018 (ECRA), 50 U.S.C. §§ 4811, et seq. This client advisory focuses on the ECRA as a new tool for enforcing U.S. national security and foreign policy interests, and explains what this means for future business compliance with U.S. law. 

The DOJ's Invocation of the ECRA

Earlier this summer, the DOJ obtained a seizure warrant for two aircraft—a $350 million aircraft Boeing 787-8 and a $60 million Gulfstream G650ER—owned by Roman Abramovich, a Russian oligarch who does not appear on the Specially Designated Nationals and Blocked Persons (SDN) list. See Seizure Warrant, In re: a Boeing 787-8 Dreamliner & Gulfstream G650ER Aircraft, No. 22-MAG-4860 (S.D.N.Y. Jun. 6, 2022).

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