The Expanding Impact of US Sanctions on Russia

What You Need to Know and Do Now

Over the past six months, the US has pieced together a complex and continuously expanding combination of export and trade controls on Russia that are unlike any US rules on any other countries.  No one wants to be the first enforcement poster child and face all of the publicity that would come with a critical violation of the new rules.  That means compliance personnel worldwide have two tasks.  First, to learn and understand the ever expanding rules.  Second, to figure out how to adjust their current compliance procedures to ensure they and their foreign affiliates comply with the rules.

Join John Black for an information-packed webinar that will teach what you need to know about the new rules and give you some practical advice for updating your compliance procedures to comply with them.  John will give you clear and concise explanations of these key elements of the new rules:

• Understanding the current focus on important Russian entities in the energy, financial and defense industries.

• Using the different OFAC Russian Sectorial Sanctions Lists (SSLs) and the unique rules under the OFAC directives applicable to dealing directly or indirectly with parties on the SSLs.

• Knowing when a party not named on an SSL is subject to the SSL rules

• Knowing how your payment terms could cause a violation of the SSL rules

• The recent additions of Russian entities to the BIS Entities List—not the same as the SSL—and seeing how the rules vary among the parties on the Entities List.

• The unique approach of basing export/reexport licensing requirements on Schedule B Numbers, which creates a new risk-based urgency to making sure you have accurate Schedule B Numbers.

• New ECCN-based license requirements for Russia.

• Imposing the longstanding China military end use rule on Russia.

• Creating a new military end user rule for Russia that goes far beyond the current China rule and applies to non-military parties in certain cases.

• License application approval policies for Russia

• Understanding the interaction of the various OFAC and BIS rules.

In addition to making sure you understand the key elements of the complex rules, John Black will also offer some practical advice to help you revise your compliance procedures so you will be in compliance with the new rules and be prepared for their future expansion.  Like everything else in the trade compliance field, it all comes down to using a risk assessment to set your priorities.  John will point out the key risks you certainly want to avoid.

Webinar participants will be invited to submit questions during the webinar; the final 30 minutes of the webinar will be allotted to answering attendees' questions. Our webinar will provide PowerPoint slides and include video and commentary from John Black, who boasts 29+ years of export compliance experience and many years of instructing experience in the compliance field.

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**Each registrant will receive a copy of the presentation, certificate of completion and access to the webinar recording.

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