U.S. Sanctions Against Russia May Have Broad Reach for NAMM Members

Highlights

Updates on sanctions as of April 6, 2022
The economic sanctions imposed by the Biden Administration in response to the Russian invasion of Ukraine may have consequences for NAMM members.
U.S. sanctions on Russia include “luxury” items, such as grand pianos.
EU, Canada, UK, Australia and New Zealand also have sanctions against Russia.
Sanctions may impact NAMM member business partners, employees or customers.
U.S. Commerce Department has imposed significant new restrictions on the transfer of technology, including telecommunications technology, software, semiconductors and computers to entities in Russia and Belarus.

U.S. sanctions are targeted at the Russian military, defense, energy and telecommunications sectors, as well as Russia’s central bank and a host of other significant Russian banks along with designated individuals. The practical implication of these sanctions means that NAMM members that have business partners, employees or customers in Russia must review whether their activities transgress U.S. sanctions along with those imposed by other countries or multi-national bodies.

Belarus is targeted under some of these sanctions, and Canada, the European Union, the United Kingdom, Australia and New Zealand have all issued their own sanctions against Russian entities and individuals as well.

How does this apply to NAMM members?

Activities that breach sanctions may include:

Payments to or from persons or entities in Russia or otherwise listed as specially designated nationals (SDNs)
Providing financing, credit or loans to persons or entities in Russia
Debt or equity investments in Russian entities
The sale of goods or services to end users in Russia
The supply of goods or raw materials from Russia

Relatedly, the U.S. Commerce Department has imposed significant new restrictions on the transfer of technology, including telecommunications technology, software, semiconductors and computers to entities in Russia and Belarus. Even allowing Russian end-users the ability to access U.S. sourced software based on a cloud service may potentially violate these restrictions. NAMM members should determine if they are engaged in any activities that may fall within these restrictions, such as the transfer of software to Russia.

On March 16, 2022, the Commerce Department published a list of “luxury goods” which cannot be exported to or within Russia and Belarus. Included In the lengthy list are grand pianos designated within HTS Code 92012.

Take action

Determine if activities and/or operations in Russia and Belarus are sanctioned including the transfer of software to Russia.
Keep a detailed record of all activities relative to sanction review and compliance.

Resources

U.S. Department of The Treasury Active Sanctions Programs
Office of Foreign Assets Control Sanctions Programs and Information
The White House Fact Sheet on Sanctions Against Russia
U.S. Department of Commerce Restricts the Export of Luxury Goods to Russia and Belarus
Imposition of Sanctions on “Luxury Goods” Destined for Russia and Belarus

Contact a member of NAMM’s Public Affairs and Government Relations team for additional assistance.