On August 23, 2024, one day before Ukraine’s Independence Day, the U.S. Department of the Treasury and the Department of State targeted nearly 400 individuals and entities that allegedly supported Russia’s efforts to wage war against Ukraine or to evade sanctions. The designations were imposed as part of a commitment made by President Biden and G7 authorities to disrupt the supply chains and payment channels utilized by Russia’s military-industrial base. The OFAC designations included nearly a dozen transactional networks that allegedly procure ammunition, military materiel, and sensitive and critical items such as advanced machine tools and electronic components for Russia’s military-industrial base. OFAC targeted individuals and entities in Russia and around the world, including in Asia, Europe, and the Middle East, that enabled Russian oligarchs and Russia’s cyber actors to evade U.S. sanctions. OFAC also targeted Russia’s technological base, Russia’s strategic metals and mining sector, and others, including Russian financial technology companies that have allegedly provided Russia’s financial sector with necessary software and IT solutions.
Of the nearly 400 designations, the State Department targeted more than 190 individuals and entities that allegedly played a role in Russia’s efforts to evade and circumvent U.S. sanctions, including designees involved in Belarusian efforts to support Russia’s war with Ukraine; those involved in Russia’s energy, metals and mining production, and exports; and Russia’s production of armed unmanned aerial vehicles (“UAVs”). The State Department designees are based in several third countries, including the People’s Republic of China (“PRC”).
All U.S. designations were issued pursuant to Executive Order 14024, as amended, for operating in the financial services, defense, manufacturing, technology, metals and mining, or transportation 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 connection with the new designations, OFAC issued five general licenses (GLs 103 – 107) under the Russian Harmful Foreign Activities Sanctions Regulations (“RuHSR”), 31 CFR part 587. General Licenses 103 and 104 permit transactions involving the import of diamond jewelry from Russia that would otherwise be prohibited by the determinations made pursuant to EO 14068. The authorizations in General License 104 are permitted through September 1, 2025. OFAC also authorized certain limited safety and environmental transactions and the unloading of cargo involving White Fox Ship Management FZCO until October 23, 2024 (GL 105); certain wind down transactions with several newly-designated entities until October 9, 2024 (GL 106); and limited safety and environmental transactions involving certain blocked persons or vessels until October 23, 2024 (EO 107).
U.S. Department of Treasury Press Release | U.S. Department of State Fact Sheet | General License 103 | General License 104 | General License 105 | General License 106 | General License 107