On February 25, the Office of Foreign Assets Control (OFAC) placed on the Specially Designated Nationals (SDN) List Russian President Vladimir Putin, Foreign Minister Sergei Lavrov, Minister of Defense Sergei Shoigu and Chief of the General Staff of the Russian Armed Forces, First Deputy Minister of Defense, and General of the Army Valery Gerasimov. Specific detail on these designations is available here.
On February 28, 2022, OFAC took further steps to restrict Russia’s access to the world’s financial markets by sanctioning the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation. In addition, OFAC placed on the SDN List the Russian Direct Investment Fund (RDIF) and its Chief Executive Officer, Kirill Dmitriev. These actions restrict or, in certain circumstances, terminate these entities access to the U.S. financial system. With this announcement OFAC issued Directive 4 under Executive Order 14024 prohibiting U.S. persons from engaging in any transactions with these Russian financial entities, including any transfer of assets to such entities or any foreign exchange transactions. General License No. 8A, however, will allow for limited continued transactions “related to energy” until June 24, 2022 with the Central Bank of Russia as well as certain other Russian financial institutions. Specific detail on these designations is available here.
With these designations to the SDN List, all property and interests in property of these persons that are in the United States or in the possession or control of U.S. persons (or their foreign branches) are blocked and must be reported to OFAC. In addition, any entities that are owned, directly or indirectly, individually or in the aggregate, 50% or more by one or more blocked persons are also blocked. Unless authorized by a general or specific license issued by OFAC, or exempt, all transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of blocked persons are generally prohibited. Dealings with blocked persons may also trigger reporting requirements pursuant to 31 C.F.R. §§ 501.603 and 501.604.