US introduces new rounds of sanctions against Russia

As an update to our previous alerts of February 24, February 25and March 15The US Treasury Department’s Office of Foreign Assets Control (OFAC) announced a new round of sanctions against Russia on March 24, a month after Russia invaded Ukraine.

This latest round of sanctions adds a significant number of entities and individuals to the list of Specially Designated Nationals and Blocked Persons imposed by OFAC. The people targeted are: (1) Russia’s defense industrial base, (2) other Russian government officials, and (3) the managing director (CEO) of the state-owned Sberbank of Russia (Sberbank). This alert provides a brief overview of additional actions and their anticipated effects.

I. RUSSIAN DEFENSE INDUSTRIAL BASE

Perhaps the most notable action in this series of sanctions is the imposition of blocking sanctions on 48 Russian defense companies.

Designations include some major Russian defense entities: Tactical Missiles Corporation JSC (KTRV) and 28 related entities; JSC NPO high precision systems; NPK Tekhmash OAO; Joint Stock Company Russian Helicopters, as well as 15 of its subsidiaries; and the Kronstadt joint-stock company. The managing director of KTRV has also been appointed. Each of the entities was targeted for their development and supply of various types of defense items, such as weapons, ammunition, helicopters, aircraft equipment or weapons, in support of the Russian invasion of the Ukraine.

The blocking sanctions also prohibit U.S. Persons from engaging in any transactions, directly or indirectly, with designated persons or entities that are 50% or more owned by such persons, and they also require the blocking of their property and interests in the property.

This action is in addition to previous sanctions and export controls already targeting Russian defense and military activities detailed in our alert of February 25. Given the various layers of sanctions and export controls that continue to develop and their widespread effects beyond Russian borders, companies should be extra careful when engaging in transactions with entities with ties. possible with the Russian defense industry.

II. RUSSIAN OFFICIALS

OFAC also nominated 328 members of the State Duma of the Federal Assembly of the Russian Federation (the State Duma), a governing body of Russia, as well as the State Duma itself, for his actions in support of Russia’s continued invasion of Ukraine.

These blocking sanctions build on a growing number of sanctions emanating from OFAC targeting the Russian government and elites linked to the President of the Russian Federation Vladimir Putin.

III. CEO of SBERBANK

Finally, OFAC issued blocking sanctions against Herman Oskarovich Gref, the CEO of Sberbank. As detailed in our alert of February 25Sberbank is a major Russian financial institution that was itself previously sanctioned by OFAC with correspondent and passing account (CAPTA) restrictions.

The additional action of sanctioning the CEO of Sberbank could have ripple effects beyond CAPTA restrictions for certain transactions. In addition to complying with any CAPTA sanctions, US persons doing business with Sberbank should therefore be alert to any involvement of Gref in the transaction. For some questions, this may require additional diligence.

IV. CONCLUSION

Our team continues to monitor ongoing developments regarding sanctions against Russia. If you have any questions regarding the sanctions discussed in this alert, please do not hesitate to contact our International Trade team.

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