... delivery to Russia. It should also be noted that the list of priority goods for export control has been expanded. Previously there were 45 items, now there
are 50 (mainly electronics)
.
Despite the fact that it is mainly small companies that are hit by secondary sanctions, the impact of sanctions on business in friendly countries should not be underestimated. For example, amendments to Executive Order 14024, introduced in December 2023, include a mechanism for imposing blocking and other US financial sanctions on financial institutions ...
... countries may face administrative and even criminal prosecution by US authorities. In other words, Washington’s blocking sanctions extend far beyond US territory. Given the still-high role of American financial institutions in the global economy, US sanctions affect many countries. Even businesses in Russia-friendly jurisdictions are forced to take the threat of secondary sanctions seriously—that is, being added to the list of blocked persons for transactions with people and structures already on this list. The risks of being involved in criminal and administrative investigations are also taken seriously, at ...
Such sanctions are unlikely to ensure the blockade of Russia desired by the Western initiators. This was not achieved even with respect to Iran, whose economy is smaller than Russia's
Another package of US sanctions has caused a stir in connection with restrictive ...
... correspondence of the participants in the transaction, as well as signals to the authorities from the manufacturing companies, which were contacted by the accused Russian citizens and their partners.
Along with criminal cases, the number of cases of secondary sanctions, that is, blocking financial sanctions for transactions in favour of previously blocked persons, is also growing. Since the beginning of 2023, the US Treasury has imposed such sanctions on people from China, India, Armenia, Kyrgyzstan, Switzerland, Liechtenstein and a number of other ...
... prosecutions. In the first case, the US Treasury simply imposes blocking sanctions on individuals and entities that are suspected of circumventing sanctions. Such measures were widely used against Russian counterparties abroad under all large packages of US sanctions in 2023. Citizens and companies from India, China, the United Arab Emirates, Switzerland, Liechtenstein, Cyprus, Malta, etc. fell under secondary sanctions. In each such case, the Americans had no problems with the official authorities of these countries. By default, it is understood that these persons acted at their own peril and risk, and not on the order of the government in their ...
... policy problems. Unlike the EU, the US has many more tools with which to influence business. Given the role of the US dollar in world trade, the size of the US market, and the concentration of a wide range of technologies in their hands, the threat of secondary sanctions and trade restrictions from their side is perceived as more serious. In addition, the US authorities have many precedents of administrative and criminal prosecution for violation of their sanctions regimes. Unlike the EU, where this practice is only being developed.
Ivan Timofeev, Dmitriy Kiku:
New Stage of EU Sanctions Policy: Extraterritorial Measures
Of course, the presence of a “big brother” like the United States is unlikely ...
... growth of the Sino-American confrontation. There were three of them during the period under review. In addition to ZTE,
Hong Kong Sojitz Limited
in 2022 and the
Jereh Group
in 2018 were fined in 2018.
This is partly due to the active use of blocking secondary sanctions by the Treasury, as well as the fact that the US Department of Commerce plays a leading role in this area, since sanctions against China to a greater extent affect the issues of technology and "dual-use" goods.
The total amount of all payments to the US Treasury amounted to a little over $5.7 billion, $5.3 billion of which was paid by financial sector ...
... sanctions regimes against Russia under the Ukrainian package. The new legal mechanism suggests that the European Union is adopting secondary sanctions similar to those used by the United States for a long time.
Ivan Timofeev:
Is It Possible to Lift Sanctions Against Russia? — No
The essence of secondary sanctions is that financial restrictions are applied for interaction with blocked persons. That is, any financial transactions with those who are already on the list are fraught with being included in the same list. The new rule does not specify ...
... and organizations were initially the key subjects of legal rules. American administrative vocabulary also includes the “enforcement actions” concept; these actions target both Americans and foreigners. Although there is no generally accepted “secondary sanctions” concept, it appears expedient to use it in this particular meaning without reducing it solely to extra-territorial measures.
Several U.S. agencies are in charge of monitoring sanctions compliance. The Department of State supervises visa prohibitions and restrictions on weapons exports. The Department of Commerce supervises compliance with restrictions on selling American goods or foreign-made goods with American-made parts....
