On October 30, 2024, the United States took action against individuals and entities around the world that enable Russia’s war against Ukraine or its military-industrial base. The U.S. Department of the Treasury’s Office of Foreign Assets Control announced the designation of 275 individuals and entities across 17 jurisdictions, including India, the People’s Republic of China (“PRC”), Switzerland, Thailand and Türkiye, for allegedly supplying the Russian military with advanced technology and equipment needed to sustain the war. OFAC also targeted Russian entities that import or produce key inputs and other materiel for Russia’s military-industrial base.
On the same day, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) added 40 foreign entities to its Entity List for allegedly supporting the Kremlin’s illegal war in Ukraine. The BIS also tightened restrictions on 49 entities for their efforts to procure high-priority U.S. branded microelectronics and other items on Russia’s behalf. In addition, the U.S. Department of State sanctioned more than 120 individuals and entities for their alleged participation in third-country sanctions evasion networks that support Russia’s illegal war. The State Department also designated several senior Russian Ministry of Defense officials that were appointed earlier this year and targeted Russia’s military-industrial base and subsidiaries of State Atomic Energy Corporation Rosatom.
The designations by the Departments of Treasury and State were imposed pursuant to Executive Order 14024, as amended, for operating in Russia’s defense and/or related materiel sectors of the Russian economy. 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.
In light of the new designations, OFAC issued several general licenses under the Russian Harmful Foreign Activities Sanctions Regulations (“RuHSR”), 31 CFR part 587, to address transactions involving new designees. OFAC issued General License 8K to authorize transactions, until April 30, 2025, that involve one or more specified entities involved in Russia’s energy sector. OFAC also issued General License 25G to authorize transactions related to telecommunications and certain internet-based communications, including transactions that would ordinarily be prohibited by Executive Order 14066 or EO 14068 as well as the processing of transactions involving certain specified foreign financial institutions. In addition, OFAC issued General License 110 to authorize wind down transactions involving certain newly-designated entities, while General License 111 authorized certain transactions related to the divestment or transfer of debt or equity, or derivative contracts, involving certain newly-designated entities. OFAC also issued General License 112 to enable, until December 14, 2024, wind down transactions and transactions involving civil aviation safety involving Shaurya Aeronautics Private Limited.
Finally, OFAC issued one new and two amended Russia-related Frequently Asked Questions. FAQ 976, which addresses whether U.S. financial institutions may process energy-related transactions involving Russian financial institutions sanctioned under EO 14024, was updated to include the new provisions and entities referenced in GL 8K. Additionally, FAQ 1040, which addresses transactions related to telecommunication and certain internet-based communications by persons designated under EO 14024, was amended to include the new provisions in GL 25G. OFAC also issued new FAQ 1198 to address the recent designation of Shreya Live Sciences Private Limited and whether U.S. persons are authorized to engage in pharmaceutical and other humanitarian-related transactions involving Shreya and its subsidiaries.
U.S. Department of Treasury Press Release | OFAC Recent Action | Bureau of Industry and Security Press Release | U.S. Department of State Fact Sheet