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Over the last several days, the United States and allies in North America, Europe, and Asia have announced a sweeping expansion of the sanctions levied against Russia and affiliated entities and individuals in the wake of Russia’s invasion of Ukraine. The additional sanctions target Russia’s largest financial institutions; impose further prohibitions related to new debt and equity for significant state-owned enterprises; and block transactions with Russian President Vladimir Putin, Minister of Foreign Affairs Sergei Lavrov, and additional Russian elites and their family members. The U.S. Commerce Department similarly implemented stringent export control restrictions that will severely restrict exports to Russia of critical U.S.-origin technologies, as well as certain foreign direct products (FDPs) of such technologies.