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On February 24, G7 leaders announced new economic commitments intended to hold Russia accountable for its war against Ukraine. The commitments include (1) keeping Russia’s sovereign assets frozen until the conflict is resolved and Russia agrees to pay for Ukraine’s long-term reconstruction; (2) agreeing to endorse economic pressure mechanisms on Russia’s energy, extractive, financial, and defense and industrial sectors; and (3) establishing an Enforcement Coordination Mechanism to counter sanctions evasion efforts, which will be chaired by the United States in the first year.

The United States, European Union, and United Kingdom also announced a series of new sanctions against Russia.

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The United States took immediate steps to implement the new G7 commitments, including:

BIS also revised Supplement No. 3 to Part 746 of the EAR to exclude Taiwan from certain controls on foreign-produced items under Section 746.8.

While the HTS-6 Codes now used in Supplement Nos. 2 and 4 are likely familiar to U.S. importers, U.S. exporters have a choice of declaring either a Schedule B code or the HTS-6 Code during the export clearance process as part of their Automated Export System (AES) filing responsibilities. Under the new rule, U.S. exporters who may have only tracked Schedule B classifications will now have to ensure that they are familiar with the HTS-6 Codes of any items they export to Belarus or Russia.

U.S. exporters will also need to carefully consider the relevance of the HTS descriptions in Supplement Nos. 2 and 4, which are only intended to assist exporters with AES filing responsibilities, but do not govern whether an item is identified in either supplement. This is a departure from the former rule under Supplement No. 4, which stated that only the items identified in the HTS Description column of this supplement are subject to the license requirement. BIS also indicated HTS codes will be easier to track for enforcement purposes.

Additionally, OFAC released four General Licenses:

OFAC also released new frequently asked questions related to the sanctions. Of note, FAQ 1118 clarifies that General License 13D does not authorize the payment of a so-called “exit tax” involving the Central Bank of the Russian Federation or the Ministry of Finance. Instead, a license may be required when a divestment involves the payment of an “exit tax.”

On February 25, the EU also introduced further economic and individual sanctions against Russia in response to the war of aggression against Ukraine (referred to as the “tenth sanctions package”).

Marking one year of conflict, the EU adopted further restrictions against Russia, including an extension of the lists of restricted items under Annex VII, Annex XI, Annex XXIII, and Annex XXI and the lists of entities connected to Russia’s military and industrial complex (now including several Iranian entities), to whom tighter export restrictions apply. The new package extends the suspension of the broadcasting licenses, introduces new reporting obligations, and introduces sanctions against three additional Russian banks.

The EU has also extended the list of partner countries that have applied a set of export control measures equivalent to those of the EU, adding Australia, Canada, New Zealand, and Norway to the United States, Japan, the UK, and South Korea.

The batch of new measures introduced as part of the tenth sanctions package includes changes to Council Regulation (EU) 833/2014, which imposes sectoral sanctions against Russia, and Council Regulation (EU) 269/2014, imposing asset freezing measures against key entities and individuals in Russia’s economic, military, and political scenes.

In addition, the new sanctions package extends the possibility for national competent authorities to authorize transactions with entities subject to a transaction ban until December 31, 2023 (instead of June 30, 2023) if the transaction is necessary for the wind-down of a joint venture or similar legal arrangements concluded before March 16, 2022. It also extends the duration of the period (until December 31, 2023) in which the competent authority may authorize transactions that are necessary for Russian state-owned entities to divest and withdraw from Union companies.

To avoid a threat to maritime safety, the new package also provides for certain exemptions for Union operators to provide pilot services to vessels in innocent passage as defined by international law.

On February 23, the Office of Financial Sanctions Implementation (OFSI) announced new asset freeze measures against 92 individuals, entities, and banks, including Bank Saint-Petersburg PJSC, Bank Uralsib PJSC, Bank Zenit PJSC, and MTS Bank PJSC. See a full list of sanctioned individuals and entities.

Additionally, OFSI announced an intention to implement new G7 commitments, including:

These measures have not yet been enacted into law.

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