Christopher Swift Discusses U.S. Agency Cooperation on Russian Restrictions

Foley & Lardner LLP partner Christopher Swift is quoted in the Anti-Corruption Report article, “New Russia Restrictions: Agency Cooperation and Industry Focus,” offering insight on new U.S. restrictions on hundreds of entities associated with Russia.

“The substantially strengthened cooperation between agencies in recent years is normal, and it is necessary,” Swift reasoned. 

Export controls, such as those enforced by Bureau of Industry and Security (BIS), constitute a more ambitious tool than sanctions in some ways, Swift said. “Economic sanctions mean limitations on dealing with certain people or places. Export controls are limitations on using certain things, including products, technology, and source code,” he explained. Sanctioning Russia does not automatically stop certain things from coming into its possession, but export controls enforced by BIS can cut off supply chains in a more sophisticated way, according to Swift. “Its jurisdiction follows the commodities and technology, not just the parties and the countries,” he added.

Swift highlighted that makers of electronic components, semiconductors, and technological items such as accelerometers, which can find their way into drones eventually supplied to Russia, are among the western products impacted by the measures.

“Western sanctions cut the regime off from finance and supplies from North America and Western Europe. But if you are a U.S. company, it’s not enough to just look at Russia. Look at where you are selling into countries where Russia has doubled down on its relationships – especially China, and also India,” Swift advised.

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