United States: OFAC amends existing and issues new General Licenses under Russia sanctions to authorize pension payments to non-US persons outside of Russia and closing individual accounts at blocked banks

Bart McMillan leads the Chicago Office’s International Trade Compliance Subpractice within the North American International Commercial Practice. He advises US and non-US companies on international trade compliance matters arising under US export controls, trade sanctions, and antiboycott rules, as well as under US customs laws with respect to classification, valuation, country of origin, free trade agreements, and the protection of intellectual property at the US border. His practice also covers anti-bribery and specialized commercial compliance issues in sales and sales promotion under the US Foreign Corrupt Practices Act (FCPA), non-US anti-bribery law, and non-US commercial laws. Mr. McMillan has been practicing with Baker McKenzie for the entirety of his legal career, and during 2004 he was located in the Washington, DC office. He is a frequent speaker on international trade compliance matters at seminars, conferences, and company training events. While pursuing his J.D. at NYU School of Law, Mr. McMillan was Staff Editor (1997-98) and Associate Editor (1998-99), New York University Law Review; and he participated in a semester exchange to the Central European University (Budapest) (Legal Studies Dep’t).

Alexandre (Alex) Lamy joined Baker McKenzie in 2009 and currently works in the Firm's International Trade Practice Group. He assists clients with sanctions and export controls (Export Administration Regulations (EAR); International Traffic in Arms Regulations (ITAR)) and he advises clients on corporate compliance matters. Alex contributes regularly to Baker McKenzie's Global Sanctions & Export Controls Update blog.
Alex was the sole US winner of the Lexology Client Choice Award for the "Trade & Customs" category in 2021 and 2022. He was recognized in Who's Who Legal 2022 Edition of its Global Guide to Trade & Customs Lawyers "for his outstanding performance facilitating clients on sanctions, export controls and compliance checks." In 2020, the same publication recognized Alex as a "leading individual" in North America on International Sanctions and the publication reported that he "attracts applause for delivering 'a practical service which understands the needs of the business'. His 'ready availability to clients, thorough research and strong presentation skills' are further acclaimed." He was also recognized in the 2019 Edition of the same publication as being "much sought after by clients who praise his 'advice of the highest quality' and add, 'He is technically very good on OFAC sanctions issues and military/dual use export controls.'" Finally, Alex was named by Financier Worldwide in “POWER PLAYERS: International Trade & Sanctions 2021 - Distinguished Advisers."
Between August 2021 and August 2023, Alex was the co-chair of the ABA Section of International Law’s Export Controls & Economic Sanctions Committee. Prior to that appointment, he served on the steering group and as a Vice Chair of the Committee, starting back in August 2011. Alex has organized multiple events regarding recent developments in US trade sanctions and export controls for the Committee.

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Iris Zhang is an associate in the Firm's International Commercial & Trade Practice Group. Iris regularly assists multinational companies on sanctions, customs and export control compliance as well as other international trade matters. Before joining the Firm, Iris worked in a Chinese law firm in Beijing on regulatory compliance and risk controls relating to Chinese anti-bribery laws and US Foreign Corrupt Practices Act.

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