Among the designees is Maria Alexeyevna Lvova-Belova, Russia’s Presidential Commissioner for Children’s Rights, accused of deporting thousands of Ukrainian children to Russia, including their forced adoption into Russian families. OFAC also re-designated Ramzan Akhmatovich Kadyrov, the leader of Russia’s Republic of Chechnya, responsible for recruiting members of mixed martial arts clubs for the war in Ukraine, who is self-described as Putin’s “foot soldier” and, since the war in Ukraine began, was promoted to the rank of “lieutenant-general.” Kadyrov was previously designated by the US in 2017 pursuant to the Seirge Magnitsky Rule of Law Accountability Act of 2012 and in 2020 pursuant to Executive Order 13818, which builds upon and implements the Global Magnitsky Human Rights Accountability Act. Several of Kadyrov’s immediate family members were also designated by OFAC. The designations also include Dmitry Sergeevich Gramashov, an officer in Russia’s Federal Security Service (FSB), who is accused of unlawfully operating in the Crimea region targeting the pro-Ukraine population, including the repression of a journalist and conducting mass searches and arrests of ethnic Crimean Tatars.
Most of the September 15 designations are imposed pursuant to EO 14024 for being an official in the Government of Russia, operating in the financial services sector of the Russian economy, or being an entity that is owned or controlled by a designated person. The Crimean court officials were designated pursuant to EO 13685 for operating in the Crimea region of Ukraine. Gramashov was not only designated pursuant to EO 13685 but also under EO 13660 for asserting governmental authority over a region of Ukraine without the authorization of the Ukrainian government.
On September 15, 2022, OFAC also issued a determination pursuant to EO 14071 which prohibits the exportation, reexportation, sale, or supply of quantum computing services by a US person to any person located in the Russian Federation. This prohibition is effective on October 15, 2022. OFAC also issued a determination pursuant to EO 14024 to identify the Russia’s quantum computing sector as sector which significantly impacts the Russian economy – a determination which enables sanctions to be imposed upon any person which operates in this sector. This action builds upon previous determinations that permit sanctions against those operating in the accounting, trust and corporate formation, management consulting, aerospace, marine, electronic, financial services, technology, and defense and related material sectors of the Russian economy.
As a result of these designations, all property and interests in property of today’s designees within the United States or within the possession or control of a US person are blocked, and US persons are generally prohibited from engaging in transactions involving the designated persons. In addition, entities owned fifty percent or more by one or more designated persons are also blocked, unless they are exempt or authorized by a general or specific license issued by OFAC.