On January 26, 2023, the US Department of Treasury’s Office for Foreign Assets Control expanded sanctions imposed upon the private military company Wagner Group and its leader Yevgeniy Prigozhin by designating 8 individuals, 16 entities, and 4 aircraft that play key roles in the Wagner Group’s support network or support defense-related entities in Russia. OFAC joined the Department of State to impose sanctions targeting Wagner’s infrastructure that supports battlefield operations in Ukraine. Pursuant to EO 14024, which authorizes sanctions with respect to specified harmful foreign activities of the Russian government, the State Department designated 5 entities and 1 individual with links to the Wagner Group and Prigozhin, including an aviation firm, propaganda organizations, and front companies used by Wagner. The State Department also designated 9 individuals and 14 entities for their status as Russian government officials, their support of Russia’s military industrial complex, or their links to previously designated persons. The State Department also identified 2 yachts and 1 aircraft as blocked property.
OFAC previously designated the Wagner Group in 2017 under EO 13660, for being responsible for or complicit in policies that threaten the security, sovereignty or territorial integrity of Ukraine. The Wagner Group was also previously designated by the State Department in November 2022 pursuant to Executive Order 14024, for operating in the defense and military equipment sector of the Russian economy. OFAC reports that the group has also been sanctioned by Australia, Canada, Japan, the UK and the EU. In its current action, OFAC is re-designating the Wagner Group as a significant transnational criminal organization pursuant to EO 13851, as amended by EO 13863, for its efforts to destabilize countries in Africa, including the Central African Republic (“CAR”) and Mali, by extorting natural resources, committing widespread human rights abuses, and engaging in serious criminal activity, including mass executions, rape and child abductions. OFAC is also re-designating the group pursuant to EO 13667, for engaging in or being complicit in acts of violence that target women and children or target schools, hospitals, or religious sites where civilians might seek refuge.
OFAC designated numerous individuals and entities associated with Wagner Group under EO 14024 or EO 13667, for their support of the group’s military operations. Several individuals and entities with links to Russia’s defense industrial complex were also designated or re-designated by OFAC pursuant to EO 14024, along with certain friends of Russian President Vladimir Putin and their family members, and two Russian officials involved in Putin’s efforts to control occupied areas of Ukraine through the use of sham annexation referendums.
As a result of the OFAC 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 50 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.