Coinciding with the first anniversary of the Russian invasion of Ukraine, the United States has imposed additional sanctions and restrictions on exports to Russia and duties on imports of certain articles from Russia into the United States. The stated goal of these actions is to "hold Russia accountable" for its invasion of Ukraine. Importantly, these actions are taken in conjunction with U.S. G7 allies and partners.

On the sanctions and controls side, the Departments of Treasury and State are implementing wide-ranging sanctions against Russian revenue-generating sectors, as well as third-party actors in Europe, Asia, and the Middle East. The Department of Commerce is also imposing additional export restrictions on Russian and third-party companies for supporting Russia's defense sector. The White House has indicated that nearly 90 companies have been added to the Entity List.

On the import side, the United States is imposing a duty of 200% on certain aluminum articles from Russia. The duties start March 10, 2023 and cover "aluminum articles that are the product of Russia and derivative aluminum articles that are the product of Russia." Separately, there will be a 200% duty starting April 10, 2023 on

aluminum articles where any amount of primary aluminum used in the manufacture of the aluminum articles is smelted in Russia, or the aluminum articles are cast in Russia, and derivative articles where any amount of primary aluminum is used in the manufacture of the derivative aluminum articles is smelted in Russia, or the derivative articles are cast in Russia.

The April 10, 2023 duties exempt imports from any country that imposes duties of at least 200% on these same Russian articles.

Finally, the White House indicated that tariffs will increase on more than 100 Russian metals, minerals, and chemical products.

Companies doing business in Russia, or with entities that may be helpful to Russia should ensure that they have closely reviewed the new sanctions and controls to ensure they do not violate U.S. law. Importers of aluminum, aluminum derivatives, and other products in which Russia is an important global supplier will need to review their supply chains closely to minimize the risk of incurring these very substantial tariffs (as well as penalties).

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