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Ukraine Conflict: How to Maintain Global Business Continuity

Government Guidance

Governments around the world are quickly responding to unfolding global events with guidance and sanctions. Morgan Lewis is closely monitoring official government responses to provide the most up-to-date information and deliver direct links as they become available.

United States

As of May 12, 2022

FAQ 1034

FAQ 1035

FAQ 1038

FACT SHEET: United States and G7 Partners Impose Severe Costs for Putin’s War Against Ukraine

Background Press Call by a Senior Administration Official on the U.S. and G7 Actions to Impose Additional Severe Costs for Putin’s War Against Ukraine

General License 25A

General License 33 (Media Wind Down)

General License 34 (Wind Down of Accounting and Trust, Corporate Formation, and Management Consulting Services)

General License 35 (Authorizing Transactions Involving Credit Rating and Auditing Services). 

Determination Pursuant to Section 1(a)(i) of Executive Order 14024 

Determination Pursuant To Section 1(a)(ii) Of Executive Order 14071 (Prohibitions Related to Certain Accounting, Trust and Corporate Formation)

Frequently Asked Questions

Expansion of Sanctions Against Russian Industry Sectors Under the Export Administration Regulations (EAR) (05/09/2022)

Russia-related General License 7A

General License 26A

General License 31

General License 32

Frequently Asked Questions

Russia-related General License 30, "Authorizing Transactions Involving Gazprom Germania GmbH Prohibited by Directive 3 under Executive Order 14024"

Ukraine-Related Sanctions Regulations, 31 C.F.R. part 589, and renaming the regulations the Ukraine-/Russia-Related Sanctions Regulations

“FACT SHEET: President Biden’s Comprehensive Proposal to Hold Russian Oligarchs and Elites Accountable”

General License 13R- Authorizing the Wind Down of Certain Transactions Necessary to Divest or Transfer Debt, Equity, or Other Holdings in GAZ Group

General License 15L- Authorizing the Wind Down of Transactions Involving GAZ Group.

Frequently Asked Questions

A Proclamation on the Declaration of National Emergency and Invocation of Emergency Authority Relating to the Regulation of the Anchorage and Movement of Russian-Affiliated Vessels to United States Ports

Russia-related Designations and Designation Update (April 20)

General License 28

General License 29

FAQ 1030

Fact Sheet: Preserving Agricultural Trade, Access to Communication, and Other Support to Those Impacted by Russia’s War Against Ukraine. 

Russia-related General License 27

Way Forward for the Global Economy

Summary of Wyden-Portman discussion draft to disallow Foreign Tax Credits for companies that pay taxes to the Russian government, and disallow other tax benefits

Russia-related General License 26 "Authorizing the Wind Down of Transactions Involving Joint Stock Company SB Sberbank Kazakhstan or Sberbank Europe AG

Russia-related Designations and Designations Updates; Issuance of Russia-related General Licenses

General License 9C 

General License 10C

General License 21A

General License 24

General License 25. 

H.R.6968 - Suspending Energy Imports from Russia Act

H.R.7108 - Suspending Normal Trade Relations with Russia and Belarus Act

Prohibiting New Investment in and Certain Services to the Russian Federation in Response to Continued Russian Federation Aggression

U.S. Treasury Escalates Sanctions on Russia for Its Atrocities in Ukraine

Russia-related Designations and Designations Updates; Issuance of Russia-related General Licenses

General License 8B

General License 9B

General License 10B

General License 21

General License 22

General License 23

Russia-related Designation; Cyber-related Designation

Treasury Sanctions Russia-Based Hydra, World’s Largest Darknet Market, and Ransomware-Enabling Virtual Currency Exchange Garantex

Russia-related Designations and Designation Removal; Cyber-related Designation; CAATSA - Russia-related Designations; Issuance of Russia-related Determination pursuant to Executive Order 14024

FACT SHEET: United States and European Commission Announce Task Force to Reduce Europe’s Dependence on Russian Fossil Fuels

General License 6A

General License 17A

General License 20

General License 25

OFAC Updated FAQs – 1029 (March 24)

Russia-related Designations; Publication of new Frequently Asked Question

Commerce Department Identifies Commercial and Private Aircraft Exported to Russia in Apparent Violation of U.S. Export Controls

Issuance of Russia-related General License 24; Publication of amended Frequently Asked Question

Russia-related Designations and Designation Update; Belarus Designation and Designation Update; Magnitsky-related Designations

Multilateral Task Force Established by Justice and Treasury to Pursue Russian Oligarchs

Issuance of new Russia-related Executive Order and related General Licenses; Publication of new and amended Frequently Asked Questions; Russia-related Designations

Imposition of Sanctions on ‘Luxury Goods’ Destined for Russia and Belarus and for Russian and Belarusian Oligarchs and Malign Actors Under the Export Administration Regulations (EAR)

Issuance of new Russia-related Executive Order and related General License 16; Publication of new and amended Frequently Asked Questions

Executive Order on Prohibiting Certain Imports and New Investments With Respect to Continued Russian Federation Efforts to Undermine the Sovereignty and Territorial Integrity of Ukraine.

FACT SHEET: United States Bans Imports of Russian Oil, Liquefied Natural Gas, and Coal

Executive Order on Prohibiting Certain Imports and New Investments With Respect to Continued Russian Federation Efforts to Undermine the Sovereignty and Territorial Integrity of Ukraine

FACT SHEET: United States Bans Imports of Russian Oil, Liquefied Natural Gas, and Coal

Message to the Congress on Prohibiting Certain Imports and New Investments With Respect to Continued Russian Federation Efforts to Undermine the Sovereignty and Territorial Integrity of Ukraine

Publication of Russia-related Frequently Asked Questions

Addition to the List of Countries Excluded from Certain License Requirements under the Export Administration Regulations (EAR)

Russia-related Designations; Issuance of Russia-related General License

Expansion of Sanctions Against the Russian Industry Sector Under the Export Administration Regulations (EAR)

Secretary Mayorkas Designates Ukraine for Temporary Protected Status for 18 Months

Export Administration Regulations: Imposition of Sanctions Against Belarus

OFAC: Issuance of Russia-related General Licenses; Publication of new and amended Frequently Asked Questions

FAA: PROHIBITION ON RUSSIAN FLIGHT OPERATIONS IN THE TERRITORIAL AIRSPACE OF THE U.S.

Russian Harmful Foreign Activities Sanctions Regulations

Issuance of Russian Harmful Foreign Activities Sanctions Regulation

Russia-related Designations; Issuance of Russia-related Directive 4 and Russia-related General License 8A

Russia-related Designations; Issuance of Russia-related Directive 4 and Russia-related General License 8A

Joint Statement on Further Restrictive Economic Measures

Russia-related Designations (Putin, Lavrov, Shoigu, Gerasimov)

FACT SHEET: Joined by Allies and Partners, the United States Imposes Devastating Costs on Russia

Commerce Implements Sweeping Restrictions on Exports to Russia in Response to Further Invasion of Ukraine

Federal Register: Implementation of Sanctions Against Russia Under the Export Administration Regulations

Russia-related Designations; Belarus Designations; Issuance of Russia-related Directive 2 and 3; Issuance of Russia-related and Belarus General Licenses; Publication of new and updated Frequently Asked Questions

Remarks by President Biden on Russia’s Unprovoked and Unjustified Attack on Ukraine

PEESA Designations; Issuance of Russia-related General License 4

Statement by President Biden on Nord Stream 2

Fact Sheet: United States Imposes First Tranche of Swift and Severe Costs on Russia

Russia-related Designations; Issuance of Russia-related Directive 1A and General Licenses; Publication of new and updated Frequently Asked Questions

Issuance of Executive Order Blocking Property Of Certain Persons And Prohibiting Certain Transactions With Respect To Continued Russian Efforts To Undermine The Sovereignty And Territorial Integrity Of Ukraine; Issuance of Ukraine-related General Licenses

FACT SHEET: Executive Order to Impose Costs for President Putin’s Action to Recognize So-Called Donetsk and Luhansk People’s Republics

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

Letter to the Speaker of the House of Representatives and the President of the Senate regarding the Blocking Property of Certain Persons and Prohibiting Certain Transactions with Respect to Continued Russian Efforts to Undermine the Sovereignty and Territorial Integrity of Ukraine

United Kingdom

As of May 12, 2022

UK punishes Putin with new round of sanctions on £1.7 billion of goods

Russia: UK sanctions major manufacturer of Russian steel

The Annex to the Financial Sanctions Notice (04/05/2022)

General Licence INT/2022/1630477

General Licence INT/2022/1424276

The Russia (Sanctions) (EU Exit) (Amendment) (No. 8) Regulations 2022

The Russia (Sanctions) (Overseas Territories) (Amendment) Order 2022  

GENERAL LICENCE - Russian Banks – UK subsidiaries - Basic needs, routine holding and maintenance, the payment of legal fees and insolvency related payments INT/2022/1280876 

GENERAL LICENCE - Russian Banks – UK subsidiaries - Basic needs, routine holding and maintenance, the payment of legal fees and insolvency related payments INT/2022/1280876

OFSI General Licence INT/2022/1438977

GENERAL LICENCE – Payments by the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation related to debt issued by them before 1 March 2022 (General Licence - INT/2022/1495176)

The Russia (Sanctions) (EU Exit) (Amendment) (No. 7) Regulations 2022

GENERAL LICENCE – Wind Down of Positions Involving Sovcomflot

Foreign Secretary announces 65 new Russian sanctions to cut off vital industries fuelling Putin’s war machine - GOV.UK (www.gov.uk)

Who is subject to financial sanctions in the UK? 

UK announces new economic sanctions against Russia

UK visa support for Ukrainian nationals

Financial sanctions targets: list of all asset freeze targets

Foreign Secretary sanctions 386 Russian lawmakers who supported Putin's invasion of Ukraine

Notice to exporters 2022/05: General Trade Licence Russia sanctions aviation insurance

The Russia (Sanctions) (EU Exit) (Amendment) (No. 6) Regulations 2022

UK Statement on Further Economic Sanctions Targeted at the Central Bank of the Russian Federation

The Russia (Sanctions) (EU Exit) (Amendment) (No. 5) Regulations 2022

The Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2022

The Russia (Sanctions) (EU Exit) (Amendment) (No. 3) Regulations 2022

The Russia (Sanctions) (EU Exit) (Amendment) (No. 2) Regulations 2022

Press Release: Further measures to move faster with sanctions and clamp down on Putin's regime

European Union

As of May 12, 2022

FAQ - Prohibition to access EU ports

Luxury Goods FAQs (05/05/2022)

Assets Freeze FAQs (05/05/2022)

Circumvention and Due Diligence FAQs (05/05/2022)

Trading FAQs (05/05/2022)

Insurance and Re-Insurance FAQs (05/03/2022)

Sale of Securities FAQs (05/03/2022)

Deposits FAQs (05/03/2022)

Council Implementing Regulation (EU) 2022/658 of 21 April 2022 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine

Council Decision (CFSP) 2022/660 of 21 April 2022 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine

COUNCIL REGULATION (EU) 2022/576

Council Regulation (EU) 2022/580 of 8 April 2022 amending Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine

Council Implementing Regulation (EU) 2022/581 of 8 April 2022 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine

Council Decision (CFSP) 2022/582 of 8 April 2022 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine

EU adopts fifth round of sanctions against Russia over its military aggression against Ukraine

Corrigendum to Council Implementing Regulation (EU) 2022/427 of 15 March 2022 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine (Official Journal of the European Union L 87 I of 15 March 2022)

Corrigendum to Council Decision (CFSP) 2022/429 of 15 March 2022 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine (Official Journal of the European Union L 87 I of 15 March 2022)

BMWK Appoints Federal Network Agency as Trustee for Gazprom Germania

Frequently asked questions: Sanctions adopted following Russia’s military aggression against Ukraine

Frequently asked questions on insurance and reinsurance related matters concerning sanctions adopted following Russia’s military aggression against Ukraine

Frequently asked questions on aviation related matters concerning sanctions adopted following Russia’s military aggression against Ukraine

Frequently asked questions on customs related matters concerning sanctions adopted following Russia’s military aggression against Ukraine

Frequently Asked Questions on export-related restrictions pursuant to Articles 2, 2a and 2b of Council Regulation No 833/2014

German BAFA FAQs

Council Implementing Regulation (EU) 2022/427 of 15 March 2022 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine

Council Regulation (EU) 2022/428 of 15 March 2022 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia's actions destabilising the situation in Ukraine

Corrigendum to Council Decision (CFSP) 2022/267 of 23 February 2022 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine (Official Journal of the European Union L 42 I of 23 February 2022)

Council Implementing Regulation (EU) 2022/408 of 10 March 2022 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine

Council Regulation (EU) 2022/394 of 9 March 2022 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine

Council Implementing Regulation (EU) 2022/396 of 9 March 2022 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine

Council Decision (CFSP) 2022/376 of 3 March 2022 amending Decision 2014/119/CFSP concerning restrictive measures directed against certain persons, entities and bodies in view of the situation in Ukraine

Council Implementing Regulation (EU) 2022/353 of 2 March 2022 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine

Council Decision (CFSP) 2022/354 of 2 March 2022 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine

Council Decision (CFSP) 2022/346 of 1 March 2022 amending Decision 2014/512/CFSP concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine

Council Regulation (EU) 2022/345 of 1 March 2022 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine

Council Regulation (EU) 2022/350 of 1 March 2022 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia's actions destabilising the situation in Ukraine

Council Decision (CFSP) 2022/351 of 1 March 2022 amending Decision 2014/512/CFSP concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine

Corrigendum to Council Decision (CFSP) 2022/337 of 28 February 2022 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine (Official Journal of the European Union L 59 of 28 February 2022)

Corrigendum to Council Implementing Regulation (EU) 2022/336 of 28 February 2022 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine (Official Journal of the European Union L 58 of 28 February 2022)

Council Implementing Regulation (EU) 2022/336 of 28 February 2022 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine

Council Decision (CFSP) 2022/337 of 28 February 2022 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine

Council Decision (CFSP) 2022/335 of 28 February 2022 amending Decision 2014/512/CFSP concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine

Council Regulation (EU) 2022/334 of 28 February 2022 amending Council Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine

EU Council partial suspension of the application of the Agreement between the European Community and the Russian Federation on the facilitation of the issuance of visas to the citizens of the European Union and the Russian Federation

Council Implementing Regulation (EU) 2022/332 of 25 February 2022 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine

Council Decision (CFSP) 2022/331 of 25 February 2022 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine

Council Regulation (EU) 2022/330 of 25 February 2022 amending Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine

Council Decision (CFSP) 2022/329 of 25 February 2022 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine

Notice to importers Imports into the Union of goods originating in the non-government controlled areas of the Donetsk and Lugansk oblasts of Ukraine 2022/C 93 I/01

Asia

As of May 12, 2022

Singapore Ministry of Foreign Affairs: Sanctions and Restrictions Against Russia in Response to its Invasion of Ukraine