On July 20, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) implemented further sanctions against Russia to restrict “access to products that support its military and war efforts; reduce Russia’s revenue from the metals and mining sector; undermine its future energy capabilities; degrade Russia’s access to the international financial system; and starve Russia of G7-produced technology needed for its technology, aerospace, and defense sectors.” An OFAC press release summarizes this latest round of sanctions and those persons and entities that have been designated and placed on the Specially Designated Nationals (SDN) List.   

In this round of sanctions toward Russia, OFAC targeted Russia’s use of third-party intermediaries and transshipment points outside of Russia to evade sanctions, as well as additional Russia companies involved in key industry/economic sectors. The targeted entities that have been placed on the SDN List include:

  • numerous entities based in the Kyrgyz Republic that have been frequent exporters of controlled electronics components and other technology to Russia;
  • various Russia-based companies who received shipments from the identified Kyrgyz entities;
  • additional Russia and non-Russia evasion facilitators and Russia-based companies that import dual-use electronic components and technology from abroad;
  • numerous additional entities involved in Russia’s munitions factories and high-technology industries that support Russia’s defense sector;
  • several additional Russian banks;
  • various entities involved in Russia’s revenue from its metals and mining industries and manufacturers of equipment and chemicals for Russia’s energy industry; and
  • 14 Russia flagged container, cargo and passenger vessels.

For additional identifying details on these newly designated individuals, entities, and vessels, the SDN List is available here.

As a result of these actions, all property and interests in property of the persons placed on OFAC’s SDN List above 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 blocked persons are prohibited unless authorized by a general or specific license issued by OFAC, or exempt. These prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any blocked person and the receipt of any contribution or provision of funds, goods, or services from any such person.

OFAC also issued two Russia-related General Licenses (GL) to allow for the wind down of activities with certain newly designated entities:

  • GL 70 – Authorizing transactions that are ordinarily incident and necessary to the wind down of transactions involving Joint Stock Company Ural Mining and Metallurgical Company through 12:01 a.m. EST, October 18, 2023.
  • GL 71 – Authorizing transactions that are ordinarily incident and necessary to the wind down of transactions involving several Russian banks through 12:01 a.m. EST, October 18, 2023.