On August 2, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) added further Russian individuals, entities and vessels to its Specially Designated Nationals (SDN) List.  The designations include numerous Russian individuals connected to Russia President Vladimir Putin, as well as multinational companies Investitsionnaya Kompaniya MMK-FINANS (an investment and financial copany) and MMK Metalurji Sanayi Ticaret Ve Liman Isletmeciligi Anonim Sirketi (aka MMK Metalurji; a steel products manufacturer).  OFAC also designated Joint Stock Company Promising Industrial and Infrastructure Technologies for reportedly attempting to facility and evade U.S. sanctions on the Russian Direct Investment Fund.

Additional identifying information on these individuals and entities sanctioned is available here. All property and interests in property of these newly designated SDN List 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.

In connection with these sanctions, OFAC has issued several revised and new Russia-related General Licenses (GL):

  • GL 40B authorizes transactions ordinarily incident and necessary to the provision, exportation, or reexportation of goods, technology, or services to ensure the safety of civil aviation for certain blocked entities listed in an annex to the GL and including UAC, Irkut and other related companies.  Use of this GL is restricted to aircraft registered in a jurisdiction solely outside of Russia and for goods, technology, or services for use on aircraft operated solely for civil aviation purposes.  This revised GL modifies the list of entities in an attached Annex.
  • GL 43A authorizes, until August 31, 2022, transactions that are ordinarily incident and necessary for the divestment or transfer of debt or equity purchased prior to June 2, 2022, and wind down of derivative contracts entered into before June 2, 2022, involving, Public Joint Stock Company Severstal or Nord Gold PLC.  This revised GL allows U.S. financial institutions to unblock covered debt or equity that was blocked on or after June 2, 2022 but before June 28, 2022, provided that the unblocked covered debt or equity is solely used to effect transactions authorized by this GL.
  • GL 47A authorizes transactions ordinarily incident and necessary to wind down any transaction involving six of the newly designated Russian entities, or any entities owned, directly or indirectly, by 50 percent or greater interest, until September 1, 2022.
  • GL 48A authorizes the divestment or transfer of debt or equity and the wind down of related derivative contracts in two designated entities, or any entities owned, directly or indirectly, by 50 percent or greater interest, until October 3, 2022.
  • GL 49 authorizes transactions ordinarily incident and necessary to wind down any transaction involving MMK Metalurji or any entity in which it owns, directly or indirectly, a 50 percent or greater interest, until January 31, 2023.