Russian Sanctions Evaluation and Export Compliance Reviews for Pending Transactions:

Since 2017 one of our most common client phone calls has been “Can I export my [Computer, Medical Device, oil drilling equipment etc…] to my distributor or end user in Russia?” In recent months the U.S. government has been tightening the regulatory noose on the Russian government and Russian industry with ties to the Russian State. Specifically new economic sanctions imposed by both the U.S. Department of Commerce, Bureau of Industry and Security as well as the Department of the Treasury, Office of Foreign Assets Control (OFAC) has created the need for exporters to navigate a complex web of regulatory sanctions in evaluating the risk profile for potential export transactions. Over the past year, at TSI Global Consulting, we have performed “deep” Consolidated List Screens and evaluated several complex pending exports against the OFAC Russian/Ukrainian sanctions as well as Parts 736, 744 and 746 of the Export Administration Regulations (“EAR”) in order to “green light” our clients exports to Russian entities. On several occasions we have had to evaluate Red Flags and in a couple of cases we have had to reject potential transactions based on the excessive risk profiles of potential Russian partners. In most cases, we can mitigate risk to a level whereby we can green light the transaction following deep Consolidated List screening [taking the OFAC 50% Rule into account] along with extensive due diligence and use of specialized end user/end use based signed certifications