On March 24, 2022, the US Department of the Treasury’s Office of Foreign Assets Control designated the Russian State Duma, 328 of its members, 48 key Russian defense companies and Herman Gref, the CEO of Sberbank, Russia’s largest financial institution – an action in line with similar actions taken recently by the EU, the UK and Canada in response to Russia’s baseless war against Ukraine. The designations of the Russian State Duma and 328 of its members were in response to their support of the Kremlin’s efforts to violate Ukraine’s sovereignty and territorial integrity by voting for treaties that recognized the independence of the so-called Donetsk People’s Republic (DNR) and Luhansk People’s Republic (LNR); these sanctions were imposed not long after OFAC’s designation of 12 members of the State Duma on March 11, 2022. In addition, 48 companies that are a part of Russia’s defense-industrial base were designated in an effort to impact the production and supply of weapons that Russia is using in its assault on the Ukrainian people and Ukraine’s infrastructure and territory. Gref, who has also been an advisor to Putin since the 1990s, was designated by OFAC as a leader or official of the Government of the Russian Federation. All of the new designations were imposed pursuant to Executive Order 14024, which authorizes sanctions against Russia for its harmful foreign activities.
OFAC also issued a new Frequently Asked Question 1029 to provide the public with guidance on how EO 14024 and other Russia-related sanctions may impact and make sanctionable certain gold-related transactions.
On the same day, OFAC issued three Russia-related general licenses, one Ukraine-related general license and updated two additional FAQs. One of the three general licenses issued pursuant to Russian Harmful Foreign Activities Sanctions Regulations (RuHSR), 31 CFR part 587, was GL 6A that authorizes 1) the export or reexport of agricultural commodities, medicine/medical devices including replacement parts or software updates to, from or transiting the Russian Federation, 2) transactions related to prevention, diagnosis or treatment of COVID-19 or 3) transactions related to ongoing clinical trials and medical research projects that were in effect prior to March 24, 2022. GL 17A, issued pursuant to RuHSR, temporarily authorizes transactions related to the import of Russian origin products into the US pursuant to written contracts entered into prior to March 11, 2022 that would otherwise be prohibited by EO 14068, allowing transactions related to alcoholic beverages and non-industrial diamonds until March 25, 2022 and transactions related to fish and seafood until June 23, 2022. Finally, GL 20, issued pursuant to RuHSR, authorizes US persons to engage in transactions necessary to facilitate the official business of third-country diplomatic or consular missions located in Russia that would otherwise be prohibited by EO 14024 or EO 14068.
OFAC issued GL 25 pursuant to EO 13685 (targeting certain persons and transactions related to Crimea) and EO 14065 (targeting certain persons and transactions related to Russian efforts to undermine the sovereignty and territorial integrity of Ukraine) to authorize certain journalistic activities in Crimea or the DNR or LNR regions of Ukraine by news reporting organizations and individuals who are US persons that are regularly employed as journalists or supporting broadcast or technical personnel.
OFAC also updated FAQ 1023 and 1024 in order to provide a general overview of the provisions in the Russia-related GL 17A and to clarify the prohibitions in EO 14068.