The Office of Foreign Assets Control announced Oct. 19 its designation of a Russian network that procured military and sensitive dual-use technologies from U.S. manufacturers and supplied them to Russian end-users, including entities on the Entity List. These technologies included advanced semiconductors and microprocessors used in fighter aircraft, ballistic and hypersonic missile systems, smart munitions, radar, satellites, and other military applications.
As a result of this designation, all property and interests in property of these persons located in the U.S. or in the possession or control of U.S. persons are blocked and must be reported to OFAC. Any entities that are owned, directly or indirectly, 50 percent or more in the aggregate by one or more of such 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 blocked or designated persons are prohibited, unless authorized by a general or specific license issued by OFAC or otherwise 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.
For more information on how to ensure your company is in compliance with U.S. export controls, please contact attorney Kristine Pirnia at (202) 730-4964 or via email.
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