March 2022

The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes the evolving situation as of Thursday, March 31 concerning current U.S. sanctions and export restrictions related to Russia and Ukraine. This post supplements our previous analysis all of which are linked at the end of today’s content.

United States Targets Russian Sanctions Evaders in the Latest Round of Designations

On March 31, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced the designation of still more entities and individuals as it expands sanctions against Russia. These parties have been designated as Specially Designated Nationals (SDN); as a general matter, U.S. persons are prohibited from conducting any transaction with an SDN.Continue Reading Russia, Ukraine: Update as of March 31

I am looking forward to presenting a panel titled “US Sanctions Update: Russia and Other Hot Topics” alongside Phil Smith of Booking.com on April 12, 2022.

The US government continues to aggressively implement and enforce economic sanctions. Russia is the current focal point, and has been the subject of an unprecedented, coordinated series of actions…

I will join a host of presenters including Josh Frank (RSM Federal), Thomas Mercer (US Army Corps of Engineers), JW Cole (Tennessee Valley Authority) and Veronica Clark (UT PTAC) for the West Tennessee Procurement Opportunities Virtual Conference on Wednesday, July 13, 2022. The virtual conference will take place from 9 A.M – 2 P.M CST…

We are looking forward to presenting a training webinar titled, “Nuts and Bolts of Teaming Agreements” for the Maryland Procurement Technical Assistance Center (Maryland PTAC). In this one-hour webinar, you will get answers to questions such as:

  • Joint venture or subcontract?
  • Mentor/protégé?
  • Will my company still be eligible for a set aside if I team?

…

I am looking forward to joining Marc Latman and John McCarthy from SGR’s Aviation Team for another engaging webinar on Russian Sanctions for the Aviation sector. The webinar will take place on Thursday, March 31, 2022 from 8 A.M – 9 A.M PT / 11 A.M – 12 P.M. ET / 4 P.M – 5 P.M London and Dublin Time.

Through its March 18, 2022 press release, the U.S. Commerce Department, Bureau of Industry and Security (BIS) put the world on notice that it intends to vigorously administer the export restrictions it announced February 24 and again on March 2, 2022 related to aircraft and aviation-related items destined for Russia/Belarus. While the March 18 press release only lists 100 aircraft, it sets the stage for future listings that could cover a much larger number of aircraft and potentially aircraft engines. These restrictions could be applied to companies and individuals, regardless of nationality, anywhere in the world. Further, March 28, 2022 marks the end of the EU-mandated wind-down period for terminating existing aviation transactions with Russian airlines.Continue Reading [WEBINAR] Live Follow-Up Q&A on Revisiting Russian Sanctions for the Aviation Sector Post-March 28

The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes the evolving situation as of Thursday, March 24 concerning current U.S. sanctions and export restrictions related to Russia and Ukraine. This post supplements our previous analysis all of which are linked at the end of today’s content.

United States Aligns with Allies, Sanctions Hundreds of Russian Lawmakers and Others

On March 24, President Biden announced that the United States will impose sanctions on “over 400 individuals and entities comprised of Russian elites, the Duma and more than 300 of its members, and defense companies.” In so doing, the United States aligns itself with the sanctions efforts of the European Union and G7 (which consists of Canada, Japan, and the UK along with several members of the EU). This continues the unprecedented multilateral effort to restrict trade with and involving Russia.Continue Reading Russia, Ukraine: Update as of March 24

I am looking forward to presenting a panel titled “Intellectual Property” at the UT Procurement Technical Assistance Center’s Spring 2022 Small Business Innovation Conference on May 5, 2022. The conference is sponsored by The University of Tennessee in cooperation with the National Science Foundation, the National Institutes of Health, and the Department of Defense.

Conference…

In a memorandum circulated during “National Sunshine Week” celebrating the importance of open government, Attorney General Merrick Garland directed heads of executive agencies and departments to favor transparency and disclosure when considering Freedom of Information Act (FOIA) requests. The memorandum was released in the wake of bipartisan calls for increased Department of Justice (DOJ) guidance on agency FOIA responses. In February, six Democrat and Republican lawmakers co-signed a letter asking the Attorney General to issue a “clear message” to improve transparency and “encourage agencies to improve FOIA implementation.” The letter cited a 2021 Government Accountability Office report finding that agency’s use of FOIA’s limited disclosure exemptions had increased 135% between 2012 and 2019. This increased reliance on exemptions drove a 76% increase in partial denials and a 10% increase in full denials of FOIA requests in the same period.
Continue Reading New FOIA Guidelines Favor Transparency

The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes the evolving situation as of Monday, March 21 concerning current U.S. sanctions and export restrictions related to Russia and Ukraine. This post supplements our previous analysis all of which are linked at the end of today’s content.

On March 18, citing publicly available information, the Bureau of Industry and Security (BIS) issued a notice (the Notice) identifying 100 commercial and private aircraft that have flown into Russia in apparent violation of the Export Administration Regulations (EAR) since March 2, 2022. BIS noted that all listed aircraft are owned or controlled by, or under charter or lease to, Russia or Russian nationals. BIS identified the aircraft by owner/operator, tail number, serial number, and aircraft type.

In publicly listing the aircraft, BIS warned that servicing these aircraft without BIS authorization by any person, regardless of location, would violate part 736.2(b)(10) of the EAR. Also known as General Prohibition 10, this EAR provision covers the taking of virtually any action with respect to an item that has been exported in violation of the EAR. BIS emphasized that violations of the EAR can lead to enforcement action and possible criminal and/or civil fines, including jail time and loss of export privileges.Continue Reading Russia, Ukraine: Update as of March 21

From the Bass, Berry & Sims Blog Network
From the Bass, Berry & Sims Blog Network

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