U.S., Allies Impose Further Sanctions, New Export Controls on Russia as Military Advances | Insights | Holland & Knight

▤ Summary

The White House and allied nations also announced restrictive measures that will prevent the Central Bank of Russia from deploying its international reserves (estimated at approximately $650 billion) in ways that undermine the impact of the sanctions. It is likely there are hundreds, to maybe thousands, of cargoes on order, now awaiting loading or in transit aboard vessels that are being financed with documentary letters of credit (DLCs) issued, confirmed or advised by sanctioned financial institutions for the benefit of exporter sellers. Even on cargoes not financed by DLCs, the bills of lading and dock receipts or other negotiable instruments and non-negotiable sea waybills issued by the ocean carriers for all sorts of shipments might present a problem when goods arrive and have to be released to consignees at destination. Exports, reexports and transfers (in-country) from the following countries are not subject to these rules: Australia, Austria, Belgium, Bulgaria, Canada, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Japan, Latvia, Lithuania, Luxembourg, Malta, the Netherlands, New Zealand, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden and the United Kingdom. Holland & Knight continues to closely follow developments in this area and assess impact on U.S. and non-U.S. businesses operating in Eastern Europe generally and the Russian Federation and Ukraine specifically.

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