Frequently Asked Questions
The increase in sanctions and other trade restrictions as a result of the conflict in Ukraine has raised new concerns and questions for organizations in international trade. To aid in efforts to help organizations overcome these challenges, we've prepared some answers to the most frequently asked questions with regards to many of the critical compliance issues related to the Russia-Ukraine Crisis.
For more information about these new sanctions and how organizations can comply with them, please visit the Russia-Ukraine Sanctions Resource Center. You can also see the listing of major sanctions imposed by the United States and the European Union and United Kingdom.
In this Article...
What are the new sanctions on Russia?
The sanctions are largely targeted at Russia's financial and key strategic industries in an effort to constrain Russia’s ability to finance their war against Ukraine.
How do the new export restrictions and sanctions relate to and build upon existing sanctions against Russia?
The new round of sanctions imposed from Feb 2022 are based upon similar sanctions programs imposed on Russia after Moscow’s annexation of Crimea in 2014. However, the new sanctions have a much larger scope in terms of the industries and individuals listed.
Do the new sanctions apply equally across all regions, or are they more strict in regions such as Donetsk, Luhansk, and Crimea?
Donetsk, Luhansk and Crimea have complete export embargoes from the U.S. Stricter restrictions are placed on those areas compared to Russia itself.
How can I help prevent my organization from violating these new sanction restrictions?
A robust sanction screening program can help to identify the potential risks to your business, while having the proper tools and procedures to perform due diligence on new or existing business partners can provide additional layers of protection.
How soon do new restrictions come in effect after the government announces them and how quickly are new lists available for screening?
Restrictions come into effect as soon as they’re published by the government. Descartes performs updates to major lists the same day they are published, helping our users to be screen against list updates and remain compliant.
How do these new restrictions impact ultimate beneficial ownership regulations, including OFAC’s ‘50% Rule’?
Any entity owned 50% or more by Russian sanctioned actors are subject to OFAC’s 50% rule, as well. With many prominent Russian individuals and entities being sanctioned, you may have noticed an uptick in new entities being impacted by these regulations.
Is it still possible to export to the individuals or entities listed in these new sanctions?
In general, the parties that are listed on the SDN list may not be transacted with or exported to. In terms of entities not listed on the SDN, we recommend some of the resources provided by the U.S. Bureau of Industry and Security regarding the new restrictions put in place: https://www.commerce.gov/news/fact-sheets/2022/02/us-department-commerce-bureau-industry-and-security-russia-and-belarus