On September 14, 2023, the US Department of the Treasury’s Office of Foreign Assets Control imposed wide-ranging new sanctions upon Russian elites and industrial base with ties to Russia’s defense sector, military and the Kremlin. In an effort to restrict Russia’s capacity to wage its war against Ukraine, OFAC imposed nearly 100 new sanctions, while the Department of State also designated more than 70 persons. Among the OFAC designees are Russian oligarch Andrei Removich Bokarev and his wife. OFAC also designated Bokarev’s business partner, Iskandar Kakhramonovich Makhmudov, a fellow tycoon who founded and owned Joint Stock Company Ural Mining and Metallurgical Company (“UMMC”), an entity previously designated by the US in July 2023. Makhmudov’s son, a UMMC official, was also designated. Other designees include Siberica Oy and Luminor Oy, two Finland-based logistics firms whose network allegedly specializes in the shipment of foreign electronics to Russia-based end-users. OFAC also designated Gabriel Temin, a French businessman who owns Siberica; Catherine Ester Temin, an Estonian national who is a deputy board member of Siberica; and four Russia-based companies that allegedly imported goods directly from Luminor.
OFAC also sanctioned a number of Russian electronics and technology companies, leading manufacturing and construction firms, and entities in the extractives industry that will contribute to Russia’s future energy revenues. In addition, OFAC designated individuals and entities that operate in Russia’s financial services sector, including two Russia-based banks and several firms that provide wealth management consulting, auditing or investment services in Russia. Two Türkiye-based companies were also designated for shipping dual-use goods to Russia.
These designations were imposed by OFAC pursuant to Executive Order 14024 for operating in key sectors of the Russian economy or for being a spouse or adult child of a person designated under EO 14024. 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 General License 72 pursuant to Russian Harmful Foreign Activities Sanctions Regulations (“RuHSR”), 31 CFR part 587. The general license authorizes wind down transactions that involve one or more of the following newly-designated entities:
- Joint Stock Company Russia Copper Company;
- Joint Stock Company United Metallurgical Company;
- Transmashholding JSC;
- Joint Stock Company Avtovaz;
- Joint Stock CompanyMoscow Automotive Factory Maskvich;
- Limited Libility Company Machine Building Plant Tonar;
- Publichnoe Aktsionernoe Obschestvo Sollers;
- Arctic Transshipment Limited Liability Company; or
- Any entity in which one of these named persons owns a 50 percent or greater interest.
General License 72 only authorizes wind down transactions until December 13, 2023, provided that any payments to a blocked entity are made into a blocked account in accordance with the RuHSR.