On March 24, 2022, President Joseph Biden announced further sanctions toward Russia involving more than 400 individuals and entities, including the Russian Duma and its members, several additional Russian oligarchs, and numerous Russian defense companies.  The sanctions were carried out pursuant to Executive Order 14024 which authorizes sanctions against Russia for its harmful foreign activities.  The sanctions include:

  • All 328 members of the Russian Duma (i.e., Russia’s legislative assembly), and sanctioning the Duma as an entity.
  • The head of Russia’s largest financial institution Sberbank (a Russian bank previously sanctioned).
  • Several Russian oligarch known to be close to Vladimir Putin, their companies and family members.
  • Seventeen board members of Russian financial institution PJSC Sovcombank (a Russian bank previously sanctioned).
  • Forty-eight Russian defense state-owned enterprises that are part of Russia’s defense-industrial base and produce weapons that have been used in Russia’s invasion of Ukraine.

As a result, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) has blocked and placed on the Specially Designated Nationals (SDN) List these Russian officials, oligarchs and companies.  OFAC’s press release provides a  background on the sanctions.  For detailed identifying information on the individuals and entities blocked and sanctioned, see here.  All property and interests in property of these designated individuals and entities that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC.  In addition, any entities that are owned, directly or indirectly, 50% or more by one or more blocked persons are also blocked. All transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or otherwise blocked persons are prohibited unless authorized by a general or specific license issued by OFAC, or exempt.

OFAC has also issued a new FAQ to address issues regarding gold-related transactions involving Russia in an effort to provide guidance in avoiding in engaging in any transactions or measures to circumvent prohibited banking/financial transactions or otherwise evade U.S. sanctions.

In a brief statement, the White House also announced the establishment of a European Union and G7 (i.e., the Group of Seven, consisting of Canada, France, Germany, Italy, Japan, the United Kingdom, and the United States) initiative which will focus on sanctions evasion.  These countries will “share information about and coordinate responses related to evasive measures intended to undercut the effectiveness and impact of our joint sanctions actions.”  The statement notes that they will engage other governments on adopting sanctions similar to those already imposed by the U.S., EU and other G7 partners.