U.S. Tariff Focus in the Limelight of Mounting Russia Sanctions Debate

Sep. 12, 2025
By: Marvin E. McPherson

An emerging gap in U.S. policy toward Russia and its surrounding sanctioned countries is adding to the difficulties for people seeking to do business the region. It has become increasingly difficult to discern the goal of various U.S. actions and what larger policy they seek to further, which makes it difficult to predict what is next.

One example of this is shown by comparing recent export actions and efforts to regulate imports. Mixed signals abound as the Treasury Department’s Office of Foreign Assets Control (OFAC) issued General License No. 11 authorizing certain transactions with Belavia Belarusian Airlines, a carrier sanctioned in 2023. The move permits activities that would normally be prohibited under the Belarus Sanctions Regulations, including transactions involving entities the airline owns by 50% or more. The license is the second such authorization since Belavia’s listing, following a temporary 2023 measure focused on civil aviation safety.

Meanwhile, on Capitol Hill, Sens. Lindsey Graham (R-S.C.) and Richard Blumenthal (D-Conn.) announced new legislation to formally designate Russia a State Sponsor of Terrorism until Moscow returns more than 19,000 Ukrainian children taken during the war. The bill would effectively bar most forms of lawful business with Russia. Graham and Blumenthal chose not to extend their terrorism-designation push to Belarus, noting Minsk’s recent release of political prisoners. But the contrast between a permissive OFAC license for Belavia and Congress’s drive for tougher sanctions underscores a widening gap in U.S. policy.

As the Trump administration focuses on tariffs as a tool to negotiate with others, and Senators grow weary of the lack of escalating sanctions, doing business in Russia and surrounding sanctioned countries continues to be challenging. If you have any questions surrounding the applicability of sanctions or export controls on your company or a particular transaction, please contact any attorney at Barnes Richardson and Colburn.