Over the past week, the Biden Administration has announced unprecedented sanctions and export controls against Russia in response to its unprovoked invasion of Ukraine. While the new sanctions act as a sword against the Russian Federation and a shield for the people of Ukraine, they also pose a minefield for US citizens engaged in international business or seeking to provide humanitarian assistance to Ukraine in its time of need. A misplaced step could lead to civil or criminal enforcement by a variety of agencies responsible for monitoring U.S. exports and international financial transactions. An understanding of the law in this area, and of the agencies that enforce it, can help you help Ukraine while avoiding regulatory action.
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