The EU and U.S. Continue to Add to Sanctions List

Jun. 26, 2023
By: Marvin E. McPherson

The United States and the European Union (EU) are actively expanding their sanctions list as part of their ongoing efforts to maintain and intensify pressure on Russia. The EU has recently adopted its 11th sanctions package, which includes the addition of over 100 individuals and entities to the sanctions entity list, and 87 new entities have been included in the list of those directly supporting Russia's military and industrial complex. To strengthen its measures, the EU package also incorporates a new anti-circumvention tool, enabling restrictions on the sale, supply, transfer, or export of specified sanctioned goods and technology to select third countries with jurisdictions considered to pose a high risk of circumvention.

Meanwhile, the United States continues to expand its own list of individuals and entities on the Office of Foreign Assets Control (OFAC)'s entity list. The EU's recent adoption of sanctions packages indicates that more initiatives can be expected from the United States as they pursue further sanctions against Russia. Consequently, it is crucial for companies to proactively conduct ongoing screening for Specially Designated Nationals (SDN) and sanctioned entities listed by U.S. sanctions. U.S. sanctions screening involves the process of verifying individuals, organizations, or entities against various sanctions lists maintained by the U.S. government. These lists typically include individuals, companies, and countries subject to economic and trade restrictions due to concerns such as terrorism, proliferation of weapons of mass destruction, human rights violations, or other illicit activities.

The purpose of sanctions screening is to ensure compliance with U.S. sanctions laws and regulations. By conducting thorough screening, organizations can identify and prevent engaging in prohibited transactions with sanctioned entities, thus mitigating legal and reputational risks. Implementing robust sanctions screening procedures is crucial for organizations to comply with U.S. sanctions regulations, as failure to do so can result in significant penalties and reputational damage. Moreover, staying up-to-date with changes and updates to the sanctions lists is essential for effective screening.

If you have questions about your companies’ sanctions compliance program or reviewing a recently acquired company’s sanctions liability do not hesitate to contact an attorney at Barnes Richardson, & Colburn LLP.