The US Department of the Treasury’s Office of Foreign Assets Control recently designated four individuals who have served on the supervisory board of the Alfa Group Consortium, one of the largest financial and investment conglomerates in Russia. OFAC also sanctioned the Russian Association of Employers the Russian Union of Industrialists and Entrepreneurs (“RSPP”), an organization that is involved in Russia’s technology sector and has some involvement in Russia’s responses to sanctions imposed since it invaded Ukraine. The designations were imposed pursuant to Executive Order 14024 for operating or having operated in the financial services or technology sector of the Russian economy.
As a result of these designations, all property and interests in property of these 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 blocked persons are also blocked.
OFAC also issued Frequently Asked Question 1131 to confirm that Letterone Holdings SA is not a blocked entity under EO 14024 because it not owned 50 percent or more by any designated person, including the newly designated members of the Alfa Group Consortium’s supervisory board.