Key Notes:

  • OFAC implemented blocking and other sanctions against major Russian and Belarusian financial institutions.
  • OFAC implemented blocking and other sanctions against state-owned enterprises, prominent government officials and other persons or entities.
  • OFAC implemented blocking sanctions targeting involvement in the Nord Stream 2 pipeline.
  • OFAC implemented sanctions related to Russian government debt.
  • The United States extended its comprehensive sanctions of Crimea to the so-called Donetsk People’s Republic (DNR) and Luhansk People’s Republic (LNR) regions of Ukraine.
  • This bulletin provides an overview of the current financial sanctions imposed against Russia and embargo of certain regions in Ukraine. Additional sanctions have been imposed through export controls and targeted sanctioning of the military industry in Russia. These measures are not covered in this bulletin.

Since the Russian invasion of Ukraine, the United States has imposed a variety of unprecedented sanctions and export controls against Russia and the two regions of Ukraine that Russia has recognized as the so-called Donetsk People’s Republic (DNR) and Luhansk People’s Republic (LNR). Many of these sanctions have also been imposed on Belarus for its support of the invasion. The European Union, the United Kingdom and other nations have also engaged in a major effort to cut Russia off from global capital markets and limit its access to certain technologies. The sanctions have primarily targeted the financial, defense and intelligence sectors of Russia and Russian-backed regions of Ukraine. In this update, we provide an overview of the first tranche of these sanctions. A bulletin covering export controls and sanctions targeting Russia’s defense and oil and gas industries is forthcoming.

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