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Timothy O'Toole Comments in Law360 on Past and Future U.S. Sanctions and Export Controls Actions Against Russia

"Sanctions Take Aim at Russia's Enablers as War Drags On"


Timothy O'Toole discussed past and future U.S. sanctions and U.S. export controls actions activity against Russia in the year since the invasion began.  Following the international sanctions ramp up last year, two options to put more pressure on Russia remain, O'Toole said. The U.S. could issue a total embargo on Russia similar to its blocks on trade with Cuba and North Korea or it could take more strident action against Russia's energy sector, though Moscow still supplies fuel to a number of U.S. allies. "Even if more blocks on Russia's energy sector are under consideration, the U.S. and its partners will likely wait to take stock of the price cap's effectiveness first," O'Toole noted, emphasizing that neither option is likely in the near-term, barring a drastic change on the ground in Ukraine. He also predicted that the slower drumbeat of sanctions is likely to continue for now, along with the multilateral coordination and the novel use of export controls as sanctions that stood out in the international response during the first year of Russia's war in Ukraine. "In my view, the most interesting and impressive thing about the last year in Russian sanctions is the level of multilateral coordination that we've seen," O'Toole said, adding "I don't think there's any program that has ever been like that. And then when you combine that with the speed, it's pretty remarkable what they were able to get done in the past year."