The U.S. Department of Commerce has announced additional export restrictions to counter Russian aggression, with the Bureau of Industry and Security (BIS) cracking down on diversion tactics. The Office of Foreign Assets Control (OFAC) has also tightened sanctions on Russia, expanding secondary sanctions risk for foreign financial institutions. These measures include sweeping new sanctions and export controls on Russia and Belarus, targeting certain software and related services. The extension of secondary sanctions to Russia's banks, such as VTB, is expected to significantly impact trade, as Russian businesses previously flocked to open accounts at VTB's Chinese branch. Now that VTB is sanctioned, it has become toxic to Chinese banks. The sanctions also encompass EAR99 software controls, and IT and software services.