On August 20, 2021, on the one year anniversary of Aleksey Navalny’s Novichock poisoning by the Russian government, the US Department of the Treasury’s Office of Foreign Assets Control in collaboration with the US Department of State and authorities in the UK, imposed additional sanctions on Russia by designating nine Russian officials/operatives and two Russian entities for their participation in Navalny’s poisoning or Russia’s chemical weapons program. The OFAC sanctions were imposed pursuant to Executive Order 13382 of June 28, 2005, “Blocking Property of Weapons of Mass Destruction Proliferators and Their Supporters.” As a result of these sanctions, all US property is blocked, and transactions with designated persons and entities are generally prohibited. In addition, any entity in the US that is owned fifty percent or more by a sanctioned person is also blocked.
At the same time, the US Department of State designated two scientific laboratories associated with Russia’s Ministry of Defense for their participation in activities to advance Russia’s chemical weapons capabilities. The new State Department sanctions were imposed pursuant to authorities in EO 14024 of April 15, 2021, “Blocking Property With Respect to Specified Harmful Foreign Activities of the Government of the Russian Federation.” In addition, UK Foreign Secretary Dominic Raab announced the imposition of restrictive measures, which include asset freezes and travel bans, upon seven Russian operatives responsible for planning or carrying out the attack on Navalny. The UK sanctions were imposed pursuant to the Chemical Weapons (Sanctions) (EU Exit) Regulations 2019.
The US actions build upon and are consistent with the measures imposed on March 2, 2021, 2018, and 2019 of the US Chemical and Biological Control and Warfare Elimination Act of 1991 (CBW Act), made in response to the poisoning of Sergey Skripal and his daughter, along with the waivers associated with these sanctions. The new sanctions imposed under the CBW Act include restrictions on permanent imports of certain Russian firearms, as well as a policy of denial for new and pending permit applications, and include additional US Department of Commerce export restrictions on nuclear and missile-related goods and technology. The CBW Act sanctions are expected to take effect on September 7, 2021 upon publication of a Federal Register notice and will remain in place for a minimum of 12 months.
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