Although many of the U.S. sanctions against Russia have been in place for months, companies are still dealing with a range of compliance challenges, Crowell & Moring trade lawyers said this week, especially involving Russia-related service restrictions. They also said they don’t expect the pace of sanctions to slow anytime soon, especially as the U.S. ramps up enforcement efforts this year.

The U.S. announced a new, sweeping set of export controls and sanctions last week to further hobble Russia on the one-year anniversary of its invasion of Ukraine, including additions to the Entity List, an expansion of industry sector restrictions on both Russia and Belarus, new export controls against Iran to address its drone transfers to Russia, and new financial sanctions against more than 100 people and entities. Many of the measures, which were announced alongside similar actions by U.S. G-7 allies, aim to “cut off the Russian defense industrial base and military from even low-technology consumer items,” the Bureau of Industry and Security said.

Vladimir Voronchenko, a Russian citizen and legal permanent resident of the U.S., was charged with participating in a scheme to net over $4 million to maintain four properties in the U.S. owned by sanctioned oligarch Viktor Vekselberg, DOJ announced. Voronchenko also tried to sell two of the properties.

The Office of Foreign Assets Control designated 10 individuals and 12 entities the agency said are related to a global sanctions evasion network that supports Russia’s military-industrial complex. The designations are part of a "strategy to methodically and intensively target sanctions evasion efforts around the globe, close down key backfilling channels, expose facilitators and enablers, and limit Russia’s access to revenue," OFAC said in a Feb. 1 news release.

The Treasury Department will prioritize most enforcement of its price cap on Russian oil against “willful violators,” a senior agency official stressed this week, reminding industry that due diligence and recordkeeping could significantly mitigate any potential penalties. Elizabeth Rosenberg, Treasury’s assistant secretary for terrorist financing and financial crimes, said the agency established its safe harbor protocol (see 2211230047) so it can target service providers intentionally looking to support Russia’s oil industry and protect those conducting good-faith sanctions compliance.

The Office of Foreign Assets Control designated a sanctions evasion network led by businessman Sitki Ayan that has allegedly facilitated hundreds of millions of dollars’ worth of oil sales on behalf of Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF), the agency said Dec. 8. The action supplements OFAC’s May 25 designations, which targeted a part of the network (see 2205250025).

The maritime industry should see an increase in Russian sanctions evasion tactics as the U.S., the EU and others prepare to set a price cap on Russian oil, said David Tannenbaum, a former sanctions compliance specialist at the Office of Foreign Assets Control. Logistics companies and others should be on the lookout for a rise in deceptive maritime practices, which could call for more compliance work and recordkeeping to avoid running afoul of U.S. sanctions, said Marco Crusafio, an international shipping lawyer with Squire Patton.

The Office of Foreign Assets Control this week issued a determination that will prohibit certain shipping services related to Russian oil, and said it will soon announce a price cap on Russian fuel alongside its G-7 partners. The agency also issued a guidance outlining how it plans to implement the price cap -- including compliance requirements for U.S. service providers -- and three related general licenses.

The Office of Foreign Assets Control sanctioned 13 companies for facilitating the sale of Iranian petrochemicals and petroleum products. The companies facilitated sales to East Asian buyers on behalf of Persian Gulf Petrochemical Industry Commercial, Triliance Petrochemical, and the National Iranian Oil Co., which are all previously sanctioned entities, OFAC said in a Nov. 17 news release. The action is the fifth round of designations targeting Iran’s petroleum and petrochemical trade since June, OFAC said.

In coordination with DOJ and the FBI, the Office of Foreign Assets Control has added one individual and two organizations to its Specially Designated Nationals list, according to an Oct. 19 notice.