On October 30, 2024, the Departments of the Treasury, State and Commerce undertook further sanctions against “enablers of Russia’s military-industrial base.” In total, the actions taken by the Office of Foreign Assets Control (OFAC) and the Bureau of Industry and Security (BIS) sanction over 300 individuals and entities involved in supplying Russia with advanced technology and equipment to continue its war against Ukraine. In addition, OFAC has designated more than 150 Russia-based defense and related materiel, technology, manufacturing, and aerospace companies that procure or produce finished military products or key components, precursors, and machinery for Russia’s war effort. According to related press releases, these actions “continue to demonstrate the importance of preventing the use of U.S.-origin and U.S.-branded products by Russia’s defense industrial base.” Deputy Secretary of the Treasury Wally Adeyemo stated, “we are unyielding in our resolve to diminish and degrade Russia’s ability to equip its war machine and stop those seeking to aid their efforts through circumvention or evasion of our sanctions and export controls.”

OFAC and State Actions

Treasury’s OFAC has sanctioned 275 individuals and entities involved in supplying Russia with advanced technology and equipment an involved in sanctions evasion networks across 17 jurisdictions, including India, the People’s Republic of China (PRC), Switzerland, Thailand, and Türkiye. In addition OFAC has designated over 150 domestic Russian importers and producers of key inputs and other materiel for Russia’s military-industrial base. The Department of State has also sanctioned parties in multiple third countries, several senior Russian Ministry of Defense officials and defense companies, and those that support the development of Russia’s future energy production and exports. State also imposed sanctions on several China-based companies exporting dual-use goods that fill critical gaps in Russia’s military-industrial base as well as entities and individuals connected to the Belarus/Lukashenka regime’s support for Russia’s defense industry. All of these individuals and entities have been placed on OFAC’s Specially Designated Nationals (SDN) List. For additional details and identifying information see here (OFAC) and here (State Department).

As a result, all property and interests in property of the designated persons 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, individually or in the aggregate, 50% or more by one or more blocked persons are also blocked. Unless authorized by a general or specific license issued by OFAC, or exempt, OFAC’s regulations generally prohibit 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. 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.

In addition, has issued several amended and new Russia-related General Licenses

  • Russia-related General License 8K, “Authorizing Transactions Related to Energy,” extending energy related transactions with the listed Russian entities until April 30, 2025.
  • Russia-related General License 25G, “Authorizing Transactions Related to Telecommunications and Certain Internet-Based Communications,” adding additional entities that are not authorized under this general license.
  • Russia-related General License 110, “Authorizing the Wind Down of Transactions Involving Certain Entities Blocked on October 30, 2024,” with a wind down deadline of no later than December 14, 2024.
  • Russia-related General License 111, “Authorizing Certain Transactions Related to Debt or Equity of, or Derivative Contracts Involving, Certain Entities Blocked on October 30, 2024,” with a wind down deadline of no later than December 14, 2024.
  • Russia-related General License 112, “Authorizing Civil Aviation Safety and Wind Down Transactions Involving Shaurya Aeronautics Private Limited,” with a wind down deadline of no later than December 14, 2024.

Certain transactions under each of these general licenses remain unauthorized and therefore each requires close analysis.

BIS Actions

BIS has issued a Final Rule adding 40 foreign entities and four addresses to the Entity List in connection with their support for the Russia’s war in Ukraine, and has tightened restrictions on 49 foreign entities that were already on the Entity List to address their procurement of high-priority U.S.-branded microelectronics and other items on behalf of Russia. These entities are located in the China, India, Malaysia, Russia, Singapore, Türkiye, Estonia, Finland, the United Arab Emirates (UAE), and the United Kingdom (UK). The additions are intended to combat the diversion of U.S.-origin or U.S.-branded products to Russia through third countries. Other additions include military end-users in Russia and companies involved in Russia’s chemical and biological weapons program. As for the four addresses being added to the Entity List, they are corporate secretary addresses in Hong Kong that have been associated with the significant transshipment of sensitive items to Russia and are linked to entities whose activities risk violating BIS controls. The Entity List (supplement no. 4 to part 744 of the EAR) identifies entities and addresses for which there is reasonable cause to believe they present a high diversion risk, have been involved, are involved, or pose a significant risk of being or becoming involved in activities contrary to the national security or foreign policy interests of the United States. Parties on the Entity List are subject to individual licensing requirements and, for these entities, BIS will now have a “policy of denial” for issuing any licenses. 

BIS has also issued a Final Rule imposing additional restrictions on the export of 9 chemical precursors used to produce riot control agents (RCAs) and chemical weapons used on the battlefield against Ukraine in violation of treaty commitments. BIS notes that “[a]lthough these chemical precursors have mostly commercial uses, Russia’s use of riot control agents as a method of warfare and the use of chemical weapon chloropicrin against Ukraine has raised concerns about Russia’s further production and weaponization of these chemicals. It is important to ensure that none of these items falls into Russia’s hands for misuse.” For the changes being made in this Final Rule, shipments of items removed from eligibility for a License Exception or export, reexport, or transfer (in-country) without a license (NLR) as a result of this action that were en route aboard a carrier to a port of export, reexport, or transfer (in-country), on November 1, 2024, pursuant to actual orders for export, reexport, or transfer (in-country) to or within a foreign destination, may proceed to that destination under the previous eligibility for a License Exception or export, reexport, or transfer (in-country) without a license (NLR), provided the export, reexport, or transfer (in-country) is completed no later than on November 1.

Both of these Final Rules are effective as of November 1, 2024.