Russia sanctions and export controls increased as a result of Ukraine invasion

In response to Russian’s invasion of Ukraine, the U.S. issued new sanctions and export controls targeting Russia’s central bank and other top financial institutions. One of these sanctions, the prohibition of any U.S. persons engaging in any transaction involving the Central Bank of the Russian Federation, will make it difficult for companies to make and receive payments for lawful business with Russia. Additionally, the U.S. Department of Commerce’s (DOC) Bureau of Industry and Security (BIS) issued new export controls Feb. 24, imposing restrictions on commodities, software and technology, including certain goods produced in other countries using U.S. technology.

“More than ever, it is essential that members understand their entire supply chain, including first, second and third tier suppliers , especially end users who have any connection with the Russian military or state enterprises,” said Christine Sohar Henter, NAFEM legal counsel, Barnes & Thornburg. “While there are currently no restrictions on export of commercial foodservice equipment and supplies to Russia, there are restrictions on technology, including microchips, that can be repurposed by the military.”

The DOC’s International Trade Administration’s Country Commercial Guide to Russia provides more information. Its Consolidated Screening List is a helpful due-diligence tool, consolidating 11 export screening lists of the Departments of Commerce, State and the Treasury into a single list of sanctions and restrictions on exports, re-exports and transfers of items. Additionally, the U.S. Department of the Treasury provides a resource center with information regarding Russia-related sanctions, particularly those pertaining to Ukraine.

These new sanctions build upon prior Russian-related sanctions already in place for Russia’s annexation of Crimea, election interference, malicious cyber activities, human rights abuses, illicit trade with North Korea, support to Syria and Venezuela, and other activities.

The NAFEM resources center also includes regularly updated information on the potential impact of the war in Ukraine on members.