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Updates to the U.S. Sanctions List and Export Control List
On October 30, the U.S. Treasury Department's Office of Foreign Assets Control (“OFAC”) and the U.S. Department of State added more than 400 companies and individuals to the sanctions lists. On the same day, the U.S. Department of Commerce's Bureau of Industry and Security (“BIS”) supplemented the Entity List (“Entity List”) comprising entities in violation of U.S. export controls.

The following entities have been added to the SDN list:

  • a number of companies from China, Turkey, Hong Kong, India, and Thailand supplying dual-purpose goods, goods for the defense sector and microelectronics to the Russian Federation,

  • technology companies from the Russian Federation, in particular, developer NPO Angstrem, IT systems integrator Giant Computer Systems LLC, and the Institute of System Programming of the Russian Academy of Sciences,

  • Rosatom group companies, such as Rosatom Digital Solutions LLC and JSC Rosatom Microelectronics,

  • companies that the OFAC believes supply products to the defense sector, in particular, tire manufacturer JSC Cordiant and JSC FAB Rassvet.

 

The rationale behind the sanctions in most cases relates to the circumvention of sanction restrictions and assistance to designated persons.

 

All persons were targeted by sanctions pursuant to Executive Order No. 14024, which means that according to the latest regulatory changes, financial institutions may be sanctioned for dealing with such persons (we discussed these changes in June).

 

The Entity List was updated to include companies from China, Malaysia, Singapore, Turkey, Estonia, UAE and Russia, which the BIS believes purchased US-made microelectronics for delivery to Russia.

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