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.

 

Photo of Scott E. Diamond** Scott E. Diamond**

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor…

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor compliance, corporate anti-boycott and antibribery compliance, national security investigations, and foreign direct investment in the United States.

**Not licensed to practice law.

Photo of Francesca M.S. Guerrero Francesca M.S. Guerrero

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some…

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some of their most challenging international transactions, involving dealings in high-risk jurisdictions or with high-risk counterparties. Francesca also counsels companies through all phases of internal investigations of potential trade and antibribery violations and represents companies across industries before related government agencies.

Photo of Samir D. Varma Samir D. Varma

Samir advises multinational corporations on export controls, economic sanctions and customs, and counsels individuals and corporations on the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws. He represents clients in enforcement actions before U.S. regulatory agencies and conducts corporate internal investigations.