Listings, Delistings and Other Developments in the Russian Sphere

The US has increasingly looked to the use of sanctions as part of its strategic approach to Russia. With the list designations that go along with that approach, seeking removal from sanctions lists has increasingly become an objective for many parties. During this event, we will review Russia-related sanctions developments, as well as key issues and considerations affecting delisting objectives.

Join FTI and ACSS as we start with a higher-level review of the Russia sanctions types (US, EU) to lay the groundwork, and then discuss some interesting developments that highlight key issues regarding the Russia-elated sanctions.

Duration: 75 minutes

Speakers: Eric J. Rudolph, Forensic & Litigation Consulting | Stephen Wilcox, Forensic & Litigation Consulting

Moderator: Natasha Bright, Reporter, ACSS

Date: Thursday, Oct 01, 2020

Time: 12:00 PM – 01:15 PM EST

05:00 PM – 06:15 PM London

06:00 PM – 07:15 PM Amsterdam

Attendees will learn about a number Russia-related developments, including:

  • CAATSA developments in connection with Nord Stream and the Turkstream pipelines
  • The OFAC Haverly case involving Russia sectoral sanctions
  • Delistings of companies affiliated with Oleg Deripaska
  • Sanctions against Rosneft affiliates in connection with Venezuela sanctions
  • The recent general license for the GAZ Group
  • Designations for election interference

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Eric J. Rudolph

Senior Director

Forensic & Litigation Consulting

Eric J. Rudolph’s work focuses on compliance with economic sanctions and U.S. export controls. An attorney by experience and training, Eric has led, managed and participated in compliance reviews domestically and internationally (North America, Europe, Middle East, Africa and Asia); internal investigations; economic and trade sanctions, International Traffic in Arms Regulations (ITAR), and Export Administration Regulations (EAR) counseling; jurisdiction and classification analyses; and training efforts. In his practice, Eric focuses on providing practical recommendations concerning risk-based assessment of compliance needs, compliance program design, investigations, audits and reviews, and support of remediation activities. Additionally, Eric has significant experience in working with companies operating under government-appointed compliance monitors/officials, including serving as part of the monitor team in a sanctions and export controls case involving criminal and civil settlements with the Department of Justice (DOJ), Office of Foreign Assets Control (OFAC) and the Bureau of Industry and Security (BIS). Eris also assisted the sanctions compliance leadership at the New York branch of one of the world’s largest banks, operating under the oversight of a monitor imposed by NYDFS, with the design and implementation of enhancements to its OFAC compliance program.

Eric’s experience with sanctions matters includes advising clients on compliance with various programs administered by OFAC; review of compliance programs; review and recommendations on screening and due diligence procedures; investigation of potential violations; advising on sanctions matters in the context of M&A due diligence and integration; and assisting with voluntary self-disclosures and remedial measures.

Previously, Eric worked in the export controls and sanctions practice of a Big 4 accounting firm and ran his own firm before joining the Big 4. Eric also worked for 15 years as an in-house lawyer, including acting as a General Counsel, with manufacturing companies in various industries and has substantial experience in advising Boards and all levels of global executive leadership and management on all aspects of compliance. In addition to sanctions and export controls compliance, Eric also has experience with anti-bribery matters (Foreign Corrupt Practices Act), including policies and procedures, investigations, voluntary disclosures and remediation; and in U.S. Customs Service matters. Eric previously served as a committee liaison to a member of the United States Trade Representative’s Advisory Committee for Trade Policy and Negotiations (ACTPN), the U.S. government’s senior trade advisory panel and, in that capacity, participated in the drafting of ACTPN reports to the President, the Congress, and the Office of the U.S. Trade Representative on several free trade agreements.

Prior to entering in-house legal practice, Eric investigated and litigated fraud cases as a government securities regulator, often working with various other state and federal law enforcement and regulatory agencies, including on high-profile cases involving Ponzi schemes that resulted in criminal convictions and abusive broker-dealer sales practices.

Stephen Wilcox

Senior Director

Forensic & Litigation Consulting

Stephen Wilcox is a Senior Director in the Export Controls and Sanctions offering at FTI Consulting based in Washington, DC. He specializes in U.S. and foreign export controls and sanctions matters, including investigations, program development, enforcement advisory, end-use check and monitoring services (Post Shipment Verifications and Pre-License Checks), Voluntary Self-Disclosures (VSDs) advisory, and restricted party list removal support services.

Prior to FTI, Stephen served 24 years in counterproliferation and export control roles for the U.S. Government. During his career, Stephen represented the United States’ national security and foreign policy interests to more than 65 countries and worked extensively with foreign federal ministries, licensing organizations, international customs services, international law enforcement agencies, and trade associations.

Stephen most recently worked as the Acting Assistant Director, Export Control Officer Program of the Bureau of Industry and Security (BIS). Stephen managed an international staff charged with coordinating a global end-use monitoring program throughout the world. Stephen worked with Export Control Officers stationed outside the U.S., local staff, BIS Field Offices and other U.S. and foreign government agencies to help global industry comply with U.S. export laws.

Stephen also served as the BIS Regional Export Control Officer at the U.S. Embassy in Moscow, Russia and at the U.S. Consulate in Frankfurt, Germany. He created secure trade relationships with foreign governments, trade associations, and industries throughout Eastern and Western Europe, Russia, Central Asia, and the Northern Middle East countries. In this capacity, he conducted end-use monitoring for BIS and, on many occasions, for the U.S. Department of State, scrutinizing thousands of international transactions for compliance with Export Administration Regulations (EAR) and the International Traffic in Arms Regulations (ITAR). Stephen also assisted numerous companies to successfully remove themselves from the BIS Entity List (EL) and Unverified List (UVL).

Prior to BIS, Stephen worked for the Naval Criminal Investigative Service (NCIS). During his tour with NCIS, he served as a Foreign Area Officer (FAO) for Russia and Eastern Europe and as a liaison to the Federal Bureau of Investigation (FBI), Homeland Security Investigations (HIS), BIS, Defense Criminal Investigative Service (DCIS), and other U.S. agencies for counterproliferation investigations, undercover operations, and other sensitive efforts. During his government service, he investigated and evaluated thousands of export-related leads involving suspicious attempts to illicitly obtain sensitive U.S. origin commodities, systems and emerging technologies by unauthorized foreign governments, organized criminal elements, and terrorist organizations.

Stephen is a veteran of the United States Air Force and served as a Russian Linguist. He is a Gold Medal recipient from the Secretary of Commerce, a Meritorious Service Award from the Assistant Secretary of Homeland Security, and an Honorary Polish Military Law Enforcement Officer from the Zandermeria.