On September 4, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control designated 10 individuals and 2 entities in response to Russia’s efforts to influence the 2024 U.S. presidential election. According to OFAC, Russian state-sponsored actors have utilized a variety of tools, including generative artificial intelligence (AI) deep fakes and disinformation, to diminish the public’s confidence in U.S. election processes and democratic institutions. OFAC further reported the Russia’s state-funded news media outlet, RT (formerly known as Russia Today), began a malign influence campaign in early 2024 that covertly recruited unwitting American influencers to support these efforts. In addition, RT allegedly used a front company to disguise Russian efforts to create misleading content intended for U.S. audiences.
The designations include several RT executives and Russian Federal Security Service (“FSB”) officer Aleksey Alekseyevich Garashchenko who is the head of RaHDit (also known as Russian Angry Hackers Did It), a pro-Kremlin hacktivist group allegedly comprised of active and former Russian intelligence officers. According to OFAC, Garashchenko works directly with Russian intelligence, members of the Russian Presidential Administration, and RT employees on malign influence operations. Two of Garaschchenko’s affiliates were also designated. OFAC also sanctioned Autonomous Non-Profit Organization (“ANO”) Dialog, a Russian nonprofit organization that leverages AI technology in online Russian disinformation; ANO Dialog Regions, a subsidiary of ANO Dialog; and their Director General Vladimir Grigoryevich Tabak who formerly held positions in the Russian Presidential Administration. OFAC reported that ANO Dialog is linked to Doppelgänger, a Russia-linked influence operation network identified in 2022, that used deep fake content to develop Russian disinformation campaigns.
All OFAC designations were imposed pursuant to Executive Order 14024, as amended, for being an entity that is owned or controlled by the Government of the Russian Federation or for being a leader or executive of such an entity. As a result of these designations, all property and interests in property of the designated persons within the United States or within the possession or control of a U.S. person are blocked, and U.S. persons are generally prohibited from engaging in transactions involving a designated person. Entities owned 50 percent or more by one or more blocked persons are also blocked.
The designations by OFAC were imposed as part of a coordinated effort with the Department of State and the Department of Justice. On September 4, 2024, the Department of State designated the operational U.S. presence of media group Rossiya Segodnya and its subsidiaries RIA Novosti, RT, TV-Novosti, Ruptly, and Sputnik, as foreign missions under the Foreign Missions Act. The Department of State also announced a new policy to restrict the issuance of visa’s to individuals engaged in covert activities on behalf of Kremlin-supported media organizations. The Department also released a $10 million Rewards for Justice offer for information related to foreign interference in a U.S. election. On the same day, the DOJ announced the ongoing seizure of 32 internet domains that were allegedly used as part of Russia’s foreign malign influence campaigns in violation of U.S. money laundering and criminal trademark laws.
In addition to the designations, OFAC also issued General License (“GL”) 25E under the Russian Harmful Foreign Activities Sanctions Regulations (“RuHSR’), 31 CFR part 587, to authorize transactions related to telecommunications and certain Internet-based communications from the United States to Russia. GL 25E, which replaces and supersedes GL 25D in its entirety, explicitly excludes from authorization any transaction involving JSC Channel One Russia, Television Station Russia-1, JSC NTV Broadcasting Company, LLC Algoritm, New Eastern Outlook, Oriental Review, Garantex Europe OU, ANO Dialog, or ANO Dialog Regions, which are designated pursuant to EO 14024. OFAC also issued Frequently Asked Question 1040 to further clarify the provisions in GL 25E.
On the same day, OFAC issued an alert that cautions foreign regulators and financial institutions regarding Russia’s efforts to evade sanctions by opening new overseas branches and subsidiaries of Russian financial institutions that are not sanctioned.
U.S. Department of Treasury Press Release | U.S. Department of State Media Note | U.S. Department of Justice Press Release | General License 25 | FAQ 1040 | OFAC Alert