ARTICLE
24 February 2022

New U.S. Economic Sanctions Against Russia

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Torres Trade Law, PLLC

Contributor

Torres Law, PLLC is an international trade and national security law firm that assists clients with the import and export of goods, technology, services, and foreign investment matters. We have extensive experience with the various regimes and agencies governing trade such as U.S. Customs and Border Protection (CBP), the Department of Commerce Bureau of Industry and Security (BIS), the Department of State Directorate of Defense Trade Controls (DDTC), the Department of Treasury Office of Foreign Assets Control (OFAC), the Department of Defense Security Service (DSS), the Committee on Foreign Investment in the United States (CFIUS), and others.
On February 21, 2022, Russian President Vladimir Putin signed two decrees recognizing the pro-Russian separatist regions of the Luhansk People's Republic" and "the Donetsk People's Republic" as independent and sovereign states.
United States International Law

Russian actions with respect to eastern Ukraine.

On February 21, 2022, Russian President Vladimir Putin signed two decrees recognizing the pro-Russian separatist regions of the Luhansk People's Republic [LPR/LNR]" and "the Donetsk People's Republic [DPR/DNR]" as independent and sovereign states. Putin also deployed Russian troops to the LPR and DPR for "peacekeeping" purposes.

On February 22, the Kremlin clarified that the decrees recognizing the LPR and DPR as independent extend to large parts of territory in eastern Ukraine that are currently held by Ukrainian forces. In addition, the Russian Federation Council voted unanimously to authorize Putin to use military force beyond Russia's borders.

U.S. government's response.

Over the past 48 hours, the U.S. government and its allies have responded to Russia's aggression in eastern Ukraine with new sanctions against Russia. On February 21, in response to the day's events, U.S. President Biden issued an Executive Order on Blocking Property Of Certain Persons And Prohibiting Certain Transactions With Respect To Continued Russian Efforts To Undermine The Sovereignty And Territorial Integrity Of Ukraine, and the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") issued new Ukraine-related General Licenses, 17-22. On February 22, the U.S. government's rhetoric surrounding Russia's recent actions turned noticeably harsher as President Biden characterized Putin's recognition of the separatist republics as an act of "political provocation" and referred to Russia's deployment of troops as "the beginning of a Russian invasion of Ukraine."

In a press conference held midday on February 22, President Biden announced the imposition of "full blocking sanctions" on two Russian financial institutions – VEB.RF and Russia's military bank (presumably, the Russian special purpose bank for serving Russian military industrial complex businesses, Promsvyazbank) – as well as "comprehensive sanctions" targeting the Russian sovereign debt market, and, to be released in the coming days, new sanctions against certain Russian elites and their family members. President Biden also announced that the U.S. worked with Germany to ensure that the controversial Nord Stream 2 oil pipeline connecting Russia to Europe would "not go forward."

Torres will continue to monitor Russia related developments and will update our readers as new developments arise.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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