Background

The Treasury Department’s Office of Foreign Assets Control announced April 12 a prohibition on the importation and entry into the U.S. (including admissions into a foreign-trade zone) of aluminum, copper, and nickel of Russian origin, except to the extent provided by law or unless licensed or otherwise authorized by OFAC. U.S. Customs and Border Protection states that prohibited products imported after April 12 will require production-level documentation to determine admissibility.

OFAC has also prohibited the exportation, re-exportation, sale, or supply, directly or indirectly, from the U.S. or by a U.S. person wherever located, of the following services to any person located in Russia: (1) warranting services for aluminum, copper, or nickel of Russian origin on a global metal exchange, and (2) services to acquire such metals as part of the physical settlement of a derivative contract.

Both of these bans exempt Russian aluminum, nickel, and copper produced prior to April 13, 2024.

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