On September 1, 2016, the Office of Foreign Assets Control (OFAC) placed sanctions on 37 new individuals and entities to prevent attempts to circumvent U.S. sanctions against Russia, help the private sector with compliance and to foster a diplomatic resolution to the conflict in Ukraine. The new list (found here) includes 17 separatists in eastern Ukraine or Russian-occupied Crimea, including 11 officials operating in Crimea.  18 companies operating in Crimea, including a number of construction, defense and maritime firms, and a Ukrainian charity were added to the Specially Designated Nationals (SDN) list.  The list includes construction companies, PJSC Mostotrest and SGM –Most OOO, which were awarded contracts to complete the Kerch Strait Bridge to connect Russia to Crimea.

The U.S. has also imposed sanctions on CJSC ABR Management for its work for Bank Rossiya. Bank Rossiya has been sanctioned by the U.S. since 2014.  OFAC has also blocked the property of numerous subsidiaries of the Bank of Moscow and Gazprombank because they are more than 50% owned by their respective parent companies.  Both banks and the named subsidiaries have been subject to US sanctions since 2014, but OFAC indicates that naming them may aid with effective sanctions compliance.

If your company has questions concerning the applicability of these recent sanctions to its business or requires advice on handling specific transactions or investments, contact Cortney Morgan or Linda Tiller.