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Financial Services Law Insights and Observations

OFAC sanctions Russian officials

Financial Crimes OFAC Department of Treasury OFAC Sanctions SDN List Of Interest to Non-US Persons Russia Department of State OFAC Designations

Financial Crimes

On August 20, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) and the Department of State joined the United Kingdom in announcing sanctions pursuant to Executive Order 13382 against nine Russian individuals and two Russian entities in connection with poisoning or Russia’s chemical weapons program under a Russian opposition leader. According to OFAC, this is the third time Treasury has used discretionary authority to respond to Russia’s use of a chemical agent against its own citizens (covered by InfoBytes here). The Department of State also designated several entities and persons pursuant to E.O. 13382 for “having engaged, or attempted to engage, in activities or transactions that have materially contributed to, or pose a risk of materially contributing to, the proliferation of weapons of mass destruction or their means of delivery” by Russia. As a result of the sanctions, all of the property and interests in property of the designated persons that are in the U.S. or in the possession or control of U.S. persons, as well as any entities that are owned 50 percent or more by the designated persons, are blocked and must be reported to OFAC. Additionally, OFAC regulations generally prohibit U.S. persons from participating in transactions with the designated persons unless exempt or otherwise authorized by an OFAC general or specific license. OFAC further warned that “any foreign person who knowingly facilitates a significant transaction or transactions for or on behalf of one of these persons risks being sanctioned.”


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