The Department of the Treasury’s Office of Foreign Asset Controls (OFAC) has issued further sanctions (see also January 15, 2025 Thompson Hine Update) to address Russia’s continued efforts to evade U.S. sanctions.   OFAC noted in a press release that this latest action “targets a sanctions evasion scheme established between actors in Russia and [China] payments for sensitive goods.  Significantly, OFAC has also redesignated a number entities so that transactions involving such previously designated entities could now trigger secondary sanctions.

Additions to the SDN List

This round of designations and additions to the Specially Designated Nationals (SDN) List includes more than 150 entities and individuals, including numerous companies in Russia’s defense industry and those supporting its military industrial base, as well as other companies across multiple countries that continue to support Russia’s efforts to evade U.S. sanctions.  For specific and detailed identifying information on each of the above entities and persons, see here.

As a result of these OFAC actions, 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.

Increasing Secondary Sanctions Risk for Transactions with Certain Russian Entities

Perhaps most importantly, the Department of the Treasury has also taken actions that could trigger secondary sanctions risks for foreign persons and financial institutions that engage in transactions with previously designated Russian entities.  Specifically, OFAC has re-designated pursuant to Executive Order (EO) 13662 almost 100 entities already designated under to EO 14024.  As a result of these entities’ designation under EO 13662, foreign persons, including foreign financial institutions, that knowingly facilitate significant transactions for or on behalf of any of these entities could be subject to mandatory secondary sanctions under the Ukraine-/Russia-related sanctions program. 

For a list of entities being designated pursuant to E.O. 13662 for operating in the financial services sector of the Russian economy, please see OFAC Annex 1.  

For a list of entities being designated pursuant to E.O. 13662 for operating in the energy sector of the Russian Federation economy, please see OFAC Annex 2.

For a list of entities being designated pursuant to E.O. 13662 for operating in the defense and related materiel sector of the Russian Federation economy, please see OFAC Annex 3.

As a result of the above actions OFAC has issued several General Licenses:

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.

**Not licensed to practice law.

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 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 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.