Background

The State Department has determined under the Countering America’s Adversaries Through Sanctions Act that the Russia-based entity KVT-RUS has knowingly sold, leased, or provided to Russia goods, services, technology, information, or support for the construction of Russian energy export pipelines. The department has therefore selected the following sanctions to be imposed against this entity effective Jan. 19, 2021.

- U.S. government departments and agencies are prohibited from issuing any specific license or granting any other specific permission or authority to export any goods or technology to this entity.

- Any transactions in foreign exchange that are subject to U.S. jurisdiction and in which this entity has any interest are prohibited.

- Any transfers of credit or payments between financial institutions, or by, through, or to any financial institution, to the extent that such transfers or payments are subject to U.S. jurisdiction and involve any interest of this entity, are prohibited.

- No person may acquire, hold, withhold, use, transfer, withdraw, transport, import, or export any property subject to U.S. jurisdiction and with respect to which this entity has any interest.

- No U.S. person may invest in or purchase significant amounts of equity or debt instruments of this entity.

- All property and interests in property of this entity that are or come within in the U.S., or that are or come within the possession or control of any U.S. person, are blocked and may not be transferred, paid, exported, withdrawn, or otherwise dealt in.

For more information on the wide range of trade restrictions the U.S. has imposed on Russia and how to ensure your company is in compliance, please contact attorney Kristine Pirnia at (202) 730-4964 or via email.

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