The following has been reported by our friends at the Law Firm of GRUNFELD, DESIDERIO, LEBOWITZ, SILVERMAN & KLESTADT LLP. Should you require any additional information on this very critical and timely subject, please contact us and we will immediately put you I touch with the key personnel at GDLSK who can help you.
In response to Russia’s invasion of Ukraine, the United States has imposed significant restrictions on exports to Russia. Effective February 24, 2022, goods covered by Categories 3-9 of the Commerce Control List (CCL) are subject to license requirements and licensing is under a “policy to deny.” The involved CCL categories cover: Electronics; Computers; Telecommunications; Information Security; Sensors and Lasers; Navigation and Avionics; Marine; and Aerospace and Propulsion. These restrictions apply to exports, re-exports, and in-country transfers. The new measures follow an Executive Order issued on February 21, 2022, which barred any transactions relating to two eastern regions of Ukraine (the so-called DNR and LNR regions).
The announced sanctions also restrict the export of nearly all goods to “military end users” or for “military end uses.” Several dozen entities and individuals (both in Russia and in Belarus) have also been added to U.S. sanction lists. Additionally, the U.S. Treasury Department is acting to prohibit Russia’s two largest banks, Sberbank and VTB Bank from processing payments through the U.S. financial system.
The situation is quite fluid at the moment and it is possible that the scope of these sanctions will evolve.
Additionally, it should be noted that, as the current situation in Ukraine continues to unfold, ocean carriers in the region are taking all necessary measures to ensure the safety of their employees, while also doing their best to keep the supply chain functioning.
As of now, virtually all ocean carriers in the region are suspending all services to Ukraine until further notice. Additionally, some carriers are also suspending services to many surrounding Black Sea ports as media outlets have reported that neutral vessels are being fired upon. Finally, in some cases, carriers are unloading cargo in nearby countries where there are safer port conditions, such as Romania, Greece and Lebanon.
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