Andrew Adams, former acting deputy assistant attorney general for DOJ's National Security Division, has joined Steptoe & Johnson as a partner in the Investigations and White-Collar Defense Practice in New York, the firm announced. Adams worked as the first director of Task Force KleptoCapture -- the interagency group tasked with enforcing U.S. sanctions on Russia in wake of the invasion of Ukraine. At DOJ, he also oversaw efforts pertaining to economic sanctions, export controls and cyber offenses tied to nation-state actors, the firm said.
The European Commission released a general guidance document on implementing due diligence practices to halt the circumvention of the sanctions on Russia. The guidance includes risk assessment of possible sanctions circumvention, due diligence best practices, circumvention red flags related to business partners and buyers, and EU sanctions whistleblower tools. The due diligence best practices section addresses the stakeholder and transaction levels and the level of the goods themselves.
The EU General Court this week upheld one application for delisting under the Russia sanctions regime and rejected six others. The court removed former Ozon CEO Aleksandr Shulgin from the sanctions list, saying his relisting was not justified. The court said that given Shulgin had resigned his post and the European Council had not looked in why listing was still proper, he was not properly sanctioned, according to an unofficial translation.
The EU added six individuals to its Global Sanctions Regime for their role in perpetuating "serious human rights violations" in Russia and Ukraine, the European Council announced. The individuals include prosecutors and judges in Russia-occupied Crimea who participated in the "politically motivated court proceedings" against journalist Vladyslav Yesypenko. The council also sanctioned two members of the Russian Federal Security Service who either tortured Yesypenko or investigated him.
The U.S. Census Bureau clarified who the ultimate consignee would be for certain scenarios, in a blog post on Sept. 7. The blog post includes a few scenarios wherein the Foreign Principal Party in Interest (FPPI) or foreign buyer is listed as the ultimate consignee, and two of those wherein "reseller/distributor" is listed as the Ultimate Consignee Type if they are reselling or distributing the goods.
Treasury Secretary Janet Yellen said despite the fact that Russia has managed to use ships and insurance companies from countries that didn't agree to a price cap on Russian oil sales, the sanction is working.
The Office of Foreign Assets Control published a previously issued general license under its Russian Harmful Foreign Activities Sanctions Regulations. The full text of the license is available in the notice.
The Supply Chain Agreement, one of the pillars of the Indo-Pacific Economic Framework for Prosperity, will ask participating countries to work together to:
A potential Indirect Source Rule that the South Coast Air Quality Management District is considering, which would affect the ports of Los Angeles and Long Beach, is necessary to avoid greater disruption from federal action should port emissions remain unaddressed, the district said in an email Sept. 1. It also said it is working with stakeholders to "come up with a proposed regulation that is feasible and can improve air quality without impacting cargo flows."
The U.K.'s Financial Conduct Authority released a review of the country's sanctions systems on Sept. 6, finding firms that carried out risk exposure assessment ahead of Russia's invasion used proper practices. The review also found many firms needing better governance and oversight, and said certain companies were "too reliant on third-party" sanctions compliance tools and didn't align their practices with U.K. sanctions rules. The review spotted various backlogs regarding sanctions screening alerts and said some firms didn't have "adequate internal expertise," the report said.