On March 3, 2022, President Joseph Biden announced that the United States was sanctioning an extensive list of “Russian elites” and their family members. In a White House press release, the president stated that, “[t]hese individuals and their family members will be cut off from the U.S. financial system, their assets in the United States will be frozen and their property will be blocked from use.” These sanctions also include the designation of several aircraft and vessels belonging to these individuals. In addition, the United States has also sanctioned a number of Russian “intelligence-directed disinformation outlets” for “enabling the Government of the Russian Federation’s efforts to spread disinformation and influence perceptions as a part of their invasion of Ukraine.”
These sanctions were implemented by the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the extensive list of these Russian elites, their family members and disinformation outlets were placed on OFAC’s Specifically Designated Nationals (SDN) List. The full list of these persons and entities 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.
OFAC also issued Russia General License 15 to clarify that the sanctioning and designation of one Russian individual does not impact a U.S. person’s ability to engage in transactions with companies owned and controlled by that individual so long as such a company is not also designated by OFAC.
Furthermore, the Department of the Treasury and the Department of Justice stated that the United States will continue to work with international partners and allies to target assets in various jurisdictions, as committed to in the joint statement by leaders on February 26, 2022.