Additional Sanctions and Export Control Restrictions Imposed on One-Year Anniversary of Russia-Ukraine Conflict

February 24, 2023, marked the one-year anniversary of the Russia-Ukraine conflict. Following the one-year anniversary, the Unites States released new, extensive measures, imposing additional sanctions on Russia. Some of the latest measures include:

• New sanctions on 22 individuals and 83 entities of the metal and mining industries, resulting in increased tariffs on U.S. imports of aluminum and other metals. The White House announced that articles of Russian aluminum will be subject to a 200% ad valorem tariff under Section 232.
• Added individuals and entities to the Specially Designated National (SDN) List to include a number of Russian banks, producers of advanced materials used for Russian defense systems including any entities operating in Russia’s aerospace, technology, and electronics sectors. Designations to dozens of individuals including government ministers, high-level officials, financial service providers, and any entities linked with energy production, advanced technology, and nuclear weapons
• An additional 86 international parties added to the entity list for activities supporting Russian military defense, including entities from Canada, China, France, Luxembourg and the Netherlands.
• Revisions to expand the scope of various Export Administration Regulations (EAR) sectors, including oil & gas, industrial items, luxury goods (including refrigerators, stoves, printers, and other, various household appliances) and chemical/biological weapon-related items.
• A shift into the “HTS-6” rule which now requires US-exporters to exclusively use the HTS-6 code (meaning the first six digits of the Harmonized Tariff Schedule rather than the Schedule B number) when determining whether an item destined to Russia or Belarus is subject to these sanctions.  The change to the HTS-6 rule from the HTS-8 or HTS-10 rule acts to expand the scope of items covered by sanctions. It does not require any reclassification by US exporters, since the HTS-6 Codes are simply the first six numbers of the HTS-8 or HTS-10 codes already in use. It is also believed that by moving to the HTS-6 Codes, exporters will be prevented from “identifying an item at the 8- or 10-digit level as a way to try to evade” existing controls. The measure is intended not only to “align” with partner’s actions, but also to further limit Russian and Belarusian access to items that enable Russia’s military capabilities and sources of revenue.

Contributor: Lindsay Swanson

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Resources: 

https://www.globaltradeandsanctionslaw.com/additional-sanctions-export-control-restrictions-anniversary-russia-ukraine-conflict/

https://www.morganlewis.com/pubs/2023/02/us-significantly-expands-export-sanctions-on-russia-and-belarus-simultaneously-adds-to-entity-list-and-tariffs