Following a meeting of the G7 Summit Leaders, on May 19, 2023, the United States and the United Kingdom announced a new round of sanctions and export controls against the Government of the Russian Federation ("Russia") to continue their efforts against key sectors of Russia's military-industrial base. These actions target procurement and evasion networks to curtail the flow of necessary resources Russia needs to maintain and fund its campaign against Ukraine. In this alert, Crowell & Moring attorneys based in our U.S. and UK offices provide a comprehensive overview of the recent multi-jurisdictional actions taken by the respective countries' government agencies.
These actions are in line with the U.S. and UK's national security and foreign policy goals of continued escalation against Russia through multi-lateral coordinated government actions by: (i) sanctioning over 300 new entities, further increasing the scope of new restrictions on an ever-growing sphere of entities determined to be supporting Russia; (ii) expanding controls on thousands of EAR99 items and services, thereby subjecting non-traditional industries to the export control and sanctions regulatory regimes; (iii) amending existing authorities to better align controls amongst the U.S., UK, and their allies; and (iv) identifying for U.S. financial institutions additional export controls evasion risks and regulatory expectations for due diligence for certain export controls-related transactions. Along with this expansion is the increased risk of enforcement actions and the correlating compliance burden on companies and financial institutions that have exposure to Russia and key sectors of its economy.
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