U.S. sanctions, enforcement actions against Russian airlines and state-owned enterprises

Sanctions as a result of the conflict in Ukraine

Sanctions as a result of the conflict in Ukraine

The United States continues to sanction Russian entities as a result of the conflict in Ukraine.

Enforcement actions against three Russian airlines

The U.S. Bureau of Industry and Security (BIS) issued orders denying the export privileges of three Russian airlines due to ongoing export violations related to comprehensive export controls on Russia imposed by the U.S. Commerce Department. 

According to the Commerce release, the three “temporary denial orders” (TDOs) terminate the right of the airlines to participate in transactions subject to the Export Administration Regulations (EAR), including exports and reexports from the United States.

The TDOs are issued for 180-days and may be renewed.

Sanctions against certain Russia state-owned enterprises

The U.S. Treasury Department announced further sanctions against Russian state-owned enterprises. Accordingly, the Office of Foreign Assets Control (OFAC) issued a release publishing Russia-related general licenses, and an updated list of specially designated nationals (SDN list).

  • General License 9C [PDF 262 KB]—Authorizing transactions related to dealings in certain debt or equity
  • General License 10C [PDF 259 KB]—Authorizing certain transactions related to derivative contracts
  • General License 21A [PDF 225 KB]—Authorizing the wind down of Sberbank CIB USA, Inc. and Alrosa USA, Inc.
  • General License 24 [PDF 222 KB]—Authorizing the wind down of transactions involving public joint stock company Alrosa
  • General License 25 [PDF 154 KB]— Authorizing transactions related to telecommunications and certain internet-based communications

According to a related Treasury release, because of these sanctions:

  • All property and interests in property of the blocked persons that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC.
  • Any entities that are owned, directly or indirectly, 50% or more by one or more blocked persons are also blocked.
  • All transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or otherwise blocked persons are prohibited unless authorized by a general or specific license issued by OFAC, or otherwise exempt.

The prohibitions include the making of any contribution or provision of funds, goods or services by, to or for the benefit of any blocked person and the receipt of any contribution or provision of funds, goods or services from any such person.

For more information, contact a professional with KPMG’s Trade & Customs services:

Doug Zuvich
Partner and Global Practice Leader
E: dzuvich@kpmg.com

John L. McLoughlin
Principal and East Coast Leader
E: jlmcloughlin@kpmg.com

Andy Siciliano
Partner and National Practice Leader
E: asiciliano@kpmg.com

Steve Brotherton
Principal and Global Export and Sanctions Leader
E: sbrotherton@kpmg.com

Luis (Lou) Abad
Principal, Washington National Tax
E: labad@kpmg.com

Irina Vaysfeld
E: ivaysfeld@kpmg.com

Amie Ahanchian
E: aahanchian@kpmg.com

Christopher Young
E: christopheryoung@kpmg.com

Gisele Belotto
E: gbelotto@kpmg.com

George Zaharatos
E: gzaharatos@kpmg.com

Andy Doornaert
Managing Director
E: adoornaert@kpmg.com

Jessica Libby
E: jlibby@kpmg.com

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