Background

To mark the one-year anniversary of Russia’s invasion of Ukraine, the U.S. has imposed new import tariffs and trade sanctions on Russia.

The White House states that since February 2022 the U.S. and more than 30 allies and partners have “developed the largest set of sanctions and export control actions ever imposed on a major economy.” For example, the U.S. has implemented or expanded more than 2,000 sanctions listings and more than 375 export control Entity Listings, including major state-owned enterprises and third-country actors. It has also imposed sanctions on Russia’s largest financial institutions and imposed increasingly expansive restrictions on military and industrial goods that could support Russia’s defense industrial base. Additionally, Congress has revoked Russia’s permanent normal trade relations status, which increased tariffs on hundreds of Russian products imported into the U.S. More information on these and other measures can be found here.

The U.S. has now announced the following additional measures to “continue holding Russia accountable for its war of aggression.”

Imports. President Biden signed Feb. 24 a proclamation increasing tariffs on more than 100 Russian metals, minerals, and chemical products to 35 percent or 70 percent (the annex to the proclamation can be found here). These increases will take effect for goods entered or withdrawn from warehouse for consumption on or after 12:01 a.m. EDT on April 1 and continue until further notice.

A separate proclamation will (1) beginning March 10, impose a 200 percent tariff on aluminum articles and derivative aluminum articles that are the product of Russia, and (2) beginning April 10, impose a 200 percent tariff on aluminum articles and derivative aluminum articles where any amount of primary aluminum used in the manufacture of those articles is smelted in Russia or the articles are cast in Russia. Read more here.

Exports. The Department of Commerce is adding nearly 90 Russian and third-country companies to the Entity List (specifics can be found here and here) for engaging in sanctions evasion and backfill activities in support of Russia’s defense sector. These listings prohibit targeted companies from purchasing items, such as semiconductors, whether made in the U.S. or with certain U.S. technology or software abroad. The DOC is also (1) taking action to align measures on industrial machinery, luxury goods, and other items with its G-7 partners and allies and (2) issuing new restrictions to prevent components found in Iranian drones from making their way onto the battlefield in Ukraine.

Sanctions. The Treasury and State departments will expand sanctions to more than 200 individuals and entities, including both Russian and third-country actors across Europe, Asia, and the Middle East. These actions will include (1) sanctions on additional actors tied to Russia’s defense and technology industry, including those responsible for backfilling Russian stocks of sanctioned items or enabling Russian sanctions evasion, (2) targeting Russia’s future energy capabilities, and (3) expanding sanctions authorities to Russia’s metals and mining sector.

For more information on these and other trade restrictions the U.S. has imposed on Russia and how to ensure your company is in compliance, please contact your ST&R professional.

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