On February 23, 2024, the eve before Russia’s full-scale invasion of Ukraine officially enters its third year, the United States issued another sanctions package against Russia, taking particular aim at Russia’s financial sector, energy production revenue streams, and military-industrial complex. Specifically, the package sanctions more than 500 entities and individuals by having them added to the Specially Designated Nationals and Blocked Persons List by the Department of the Treasury and the Department of State, respectively, while the Department of Commerce imposes new export restrictions against nearly 100 entities by adding them to the Entity List maintained by the Bureau of Industry and Security. The targeted entities and individuals span across Europe, East Asia, Central Asia, and the Middle East, and are known for supplying critical technology and equipment to Russia’s military and for evading sanctions. Additionally, some of the targeted individuals were sanctioned because they were connected to the death of prominent opposition leader Aleksey Navalny, who died under mysterious circumstances in a Russian prison last week.

Perhaps the most notable inclusion in the sanctions package is the state-owned National Payment Card System Joint Stock Company, which operates Russia’s national payment system, known as Mir. Nonetheless, the package also targets two of Russia’s largest companies by revenue: SUEK, a transportation and logistics operation company that serves the Russian military, and Mechel, a major producer of specialty steels. The sanctions also target SPB Bank, which is owned by SPB Exchange—Russia’s second-largest stock exchange specializing in trading foreign shares—as well as companies involved in the Arctic LNG 2 energy project, and various manufacturers of weapons, metals, lubricants, industrial chemicals, electronics, robotics, ball bearings, and batteries used by the Russian military.

The United States did not act alone to escalate economic pressure on Russia this week.  Adopting its 13th sanctions package against Russia on February 23, 2024 as well, the European Union designated about 200 entities and individuals connected to Russia’s weapons procurement network. Similarly, Canada also imposed sanctions against 153 entities and 10 individuals known to support the Russian military through finance, logistics, and sanctions evasion on February 23, 2024. And earlier in the week, the United Kingdom levied 50 new sanctions against parties linked to Russia’s ammunition supply chain, and targeted 6 individuals known to oversee the Arctic prison colony where Navalny died. Notwithstanding the multilateral sanctions package imposed by the United States and Europe this week, though, there are still ongoing debates by the western allies about enacting even more aggressive measures to stymie Russia’s economic abilities to continue its full-scale invasion of Ukraine.

Still, the U.S. sanctions package to mark the second anniversary of Russia’s full-scale invasion of Ukraine is significant because it aligns with the ongoing trend of the United States and its allies to levy sanctions and export restrictions against Russia on each anniversary of the invasion. See Update of February 24, 2023 and Update of February 24, 2023, respectively.

Photo of Francesca M.S. Guerrero Francesca M.S. Guerrero

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some…

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some of their most challenging international transactions, involving dealings in high-risk jurisdictions or with high-risk counterparties. Francesca also counsels companies through all phases of internal investigations of potential trade and antibribery violations and represents companies across industries before related government agencies.

Photo of Samir D. Varma Samir D. Varma

Samir advises multinational corporations on export controls, economic sanctions and customs, and counsels individuals and corporations on the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws. He represents clients in enforcement actions before U.S. regulatory agencies and conducts corporate internal investigations.

Photo of Aaron C. Mandelbaum Aaron C. Mandelbaum

Aaron focuses his practice on advising clients on compliance with international economic sanctions, export controls, and U.S. import laws and regulations. He is also involved in assisting clients with complex cross-border transactions, anti-dumping and countervailing duty litigation, utilization of international and preferential trade…

Aaron focuses his practice on advising clients on compliance with international economic sanctions, export controls, and U.S. import laws and regulations. He is also involved in assisting clients with complex cross-border transactions, anti-dumping and countervailing duty litigation, utilization of international and preferential trade agreements, and customs classifications. Most recently, Aaron has counseled clients navigating requirements under the Export Administration Regulations.

Photo of Scott E. Diamond** Scott E. Diamond**

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor…

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor compliance, corporate anti-boycott and antibribery compliance, national security investigations, and foreign direct investment in the United States.