The United States is engaging in a new form of warfare. Russia invaded Ukraine just over two months ago and, rather than join the fight directly by sending troops to defend Ukraine, the United States is fighting indirectly by engaging in unprecedented financial warfare against the Russian Federation. The initial export and sanctions actions were swift and severe – but somewhat expected. As the invasion persists, the U.S. Federal Government and individual States also have begun to leverage procurement policy to amplify the financial harm to Russia. This Guide will try to help make sense of the current efforts targeting Russia, the potential impact to government contractors, and proactive steps to mitigate risk.
Before we get to the specific issues government contractors will face with respect to Russia, we should lay out a bit of a landscape. We have covered the broader restrictive measures on Russia here and have updated them steadily as those measures have broadened and deepened.
Generally, U.S. export controls prohibit nearly all exports of U.S.-origin items to Russia, and U.S. sanctions prohibit U.S. persons from transacting—directly or indirectly—with a host of Russian persons, businesses, and financial institutions, as discussed in greater detail below.
The increased Russia sanctions will present a compliance concern, but most companies with solid protective measures already in place will not need to change...
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