The US Department of the Treasury’s Office of Foreign Assets Control and the US Department of State have issued several hundred sanctions targeting individuals and entities within Russia’s domestic industrial base, along with those who supply technology and equipment to support Russia’s war against Ukraine. OFAC’s designations were issued pursuant to Executive Order 14024, which authorizes the designation of persons operating in the technology, defense, or other sectors of the Russian Federation who are involved in malicious cyber-enabled activities, election interference, transnational corruption, violent crime against US nationals and allies, activities that undermine the peace and security of the United States and its allies, or sanctions evasion.
Among those designated are individuals and entities in the People’s Republic of China, Türkiye, Switzerland, Cyprus, Luxembourg, Singapore, the Russian Federation, and the United Arab Emirates. They include:
- Turkish electronics manufacturers and suppliers;
- procurement channels for the Russian intelligence services;
- logistics and communications companies and aircraft parts suppliers in the United Arab Emirates;
- Oman- and UAE-based financial services and investment firms and several Russian Cypriot, Irish and Latvian nationals active in the direction and operation of these companies;
- Chinese radar and optical equipment suppliers;
- an industrial equipment supplier based in Switzerland, and the company’s Swiss CEO;
- sanctions evasions networks operating out of Russia and Cyprus;
- construction, aviation, and transportation companies based in the Russian Federation;
- dozens of Russian manufacturing companies involved in metalworking, 3D printing, robotics, industrial machinery, and carbon composite materials for use in the aerospace sector;
- one of Russian’s largest publicly-traded diversified holding companies, along with its subsidiaries Luxembourg, Singapore and Russia, and;
- several Russian banks and one of their chairmen.
As a result of these sanctions, all property and interests in property of the 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 a designated person. In addition, entities owned 50 percent or more by one or more blocked persons are also blocked.
In conjunction with these designations, OFAC has issued several General Licenses, all designed to remain in effect through January 31, 2024:
- General License 13G, which replaces and supersedes General License 13F, and authorizes certain administrative transactions otherwise prohibited by Directive 4 under Executive Order 14024 concerning transactions with the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation;
- General License 74, which authorizes the wind down and rejection (rather than blocking) of transactions involving the newly-designated East-West United Bank, a Luxembourg-based subsidiary of Sistema Public Joint Stock Financial Corporation, a Russian diversified holding company;
- General License 75, which authorizes certain transactions related to debt or equity of, or derivative contracts involving some of the newly-blocked entities, and;
- General License 76, which allows for the wind-down of transactions involving certain of the newly-blocked entities.