Citing Russia’s shift to a "full war economy,” the United States imposed sweeping new sanctions and export controls on Russia and Belarus on June 12, 2024, including companies and individuals that continue to supply Russia’s economy.

The new sanctions include restrictions on the supply of enterprise and industrial software and services, a ban on the provision of IT consultancy and design services, a prohibition on the supply broad range of EAR99 goods, over 300 newly sanctioned parties, and new secondary sanctions, among other updates and amendments.

This announcement reflects a continuing focus by the Office of Foreign Assets Control (OFAC) and the Bureau of Industry and Security (BIS) to counter Russia’s access to goods, software, and services that can provide material support for its war efforts, along with intense focus on third country circumvention channels.

Potentially impacted companies, particularly in the enterprise software and services sector, should carefully review these developments.  Additional details are available in our full client advisory.