On December 20, 2016, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued its latest round of Russian sanctions as part of the ongoing U.S. response to Russia’s 2014 annexation of Ukraine’s Crimean peninsula and its subsequent escalation of conflict in the region. The new sanctions target seven individuals, eight entities, and two vessels. OFAC also added an additional 26 subsidiaries of Russian banks already subject to sanctions to the U.S. Sectoral Sanctions List. The new sanctions come one day after the European Union extended its sanctions against Russia for an additional six months.
Six of the sanctioned individuals provide financial, material, or technological support to Bank Rossiya, ABR Management, or Sobinbank. The seventh individual has significant business ties to the Russian Ministry of Defense and is associated with a company that holds a contract to build a military base near the Ukrainian border to support Russian troop movements into Ukraine. In response to the new U.S. sanctions, Kremlin spokesman Dmitry Peskov expressed disappointment and indicated that Russia would take “adequate measures” to address the expanded sanctions, but did not provide any specifics.
OFAC also issued General License No. 11, authorizing certain transactions that are ordinarily incident and necessary to requesting, contracting for, paying for, receiving, or utilizing a project design review or permit from FAU Glavgosekspertiza Rossii’s offices in Russia. The general license does not authorize the transfer of any property or debiting of any account blocked pursuant to any existing sanctions.
The full Specially Designated Nationals (SDN) List of banned entities can be found here. The full Sectoral Sanctions Lists can be found here.
For guidance on navigating any of the U.S. sanctions programs and ensuring your business is in compliance with U.S. export regulations, contact Cortney Morgan or Linda Tiller or Grant Leach.