The U.S. announced May 1 additional sanctions related to Russia’s ongoing war against Ukraine, with targets including Chinese and other companies said to be contributing to Moscow’s capability to conduct that war.

For more information on how these sanctions may affect your business, please contact attorney Kristine Pirnia at (202) 730-4964 or via email.

State Department

The State Department has imposed sanctions on (1) several Chinese producers and exporters that have supplied dual-use aerospace, manufacturing, and technology equipment to entities in Russia, (2) multiple companies in Türkiye, Kyrgyzstan, and Malaysia that have shipped items on the Bureau of Industry and Security’s common high-priority list to companies based in Russia, and (3) dozens of Russian entities and individuals engaged in the development of Russia’s future energy, metals, and mining production and export capacity; sanctions evasion and circumvention; and furthering Russia’s ability to wage war against Ukraine.

All property and interests in property of the sanctioned persons that are in the U.S. or in the possession or control of U.S. persons are blocked and must be reported to the Treasury Department’s Office of Foreign Assets Control. All individuals or entities that have ownership, either directly or indirectly, 50 percent or more by one or more blocked persons are also blocked.

All transactions by U.S. persons or within (or transiting) the U.S. 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 exempt. These 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.

Further, State has reimposed restrictions on foreign military financing, U.S. government lines of credit, and export licenses for defense articles and national security-sensitive items going to Russia in the wake of Russia’s use of a chemical weapon against Ukrainian troops.

Treasury Department

OFAC is imposing sanctions on (1) major Russian importers of cotton cellulose, nitrocellulose, and key inputs to nitrocellulose (e.g., cotton pulp), (2) two China-based suppliers sending such substances to Russia, (3) nearly 60 targets in China, Azerbaijan, Belgium, Russia, Slovakia, Türkiye, and the United Arab Emirates that help Russia acquire key inputs for weapons or defense-related production, (4) more than 100 entities operating in Russia’s technology, defense and related materiel, manufacturing, or transportation sectors, (5) three Russian entities and two individuals involved in procuring items for military institutes involved in Russia’s chemical and biological weapons programs, and (6) two Russian entities involved in natural gas-related projects.

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