U.S. Eases Sanctions Transition, Warns Businesses on Russia
The U.S. Treasury's Office of Foreign Assets Control (OFAC) has published four new general licenses to ease the transition to updated sanctions. These licenses, numbered 88, 89, 90, and 91, will expire on April 8, 2024, and May 23, 2024, respectively. This move comes amidst historic sanctions imposed on Russia and entities transacting with it, marking the two-year anniversary of Russia's invasion of Ukraine and the death of opposition leader Alexei Navalny.
The U.S. Bureau of Industry and Security (BIS) has also taken significant steps. It increased the common high-priority items list from 45 to 50, highlighting the risk of certain machine tools being diverted to Russia. Additionally, BIS added 93 entities to its Entity List, with 63 based in Russia and 32 receiving a 'footnote 3' designation as Russian-Belarusian military end-users. In a related move, the U.S. government released an official business advisory, 'Risks and Considerations for Doing Business in the Russian Federation and Russia-Occupied Territories of Ukraine', to guide businesses navigating the complex landscape.
OFAC has also added almost 300 entities to its SDN List, including the National Payment Card System Joint Stock Company (NSPK) and the Joint Stock Company Sovcomflot. Meanwhile, in a separate development, 23 Chinese companies were added to the U.S. government’s Entity List on September 25, 2025, as part of expanded export control restrictions, although the specific names of these companies have not been published.
These actions reflect the U.S.'s ongoing commitment to addressing the evolving situation in Ukraine and its relations with Russia. The sanctions and export controls aim to limit Russia's access to critical technologies and financial systems, while the business advisory seeks to inform U.S. companies about the risks and challenges of operating in Russia and Russian-occupied territories.
