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Financial Services Law Insights and Observations

President Biden issues executive order blocking certain Russian pipelines

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

Financial Crimes

On August 20, President Biden signed Executive Order (E.O.) Blocking Property with Respect to Certain Russian Energy Expert Pipelines to take additional steps with respect to the national emergency declared in E.O. 14024 (covered by InfoBytes here) related to specific harmful foreign activities by the Russian government. The new E.O. prohibits, among other things, (i) “the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any person whose property and interests in property are blocked pursuant to this order”; and (ii) “the receipt of any contribution or provision of funds, goods, or services from any such person.” Concurrently, OFAC issued Russia-related General License (GL) 1A, as well as several new and updated FAQs related to the updated designations (see FAQs 894, 919, 920, and 921). Specifically, GL 1A authorizes certain activities involving the Federal State Budgetary Institution Marine Rescue Service (MRS) (“or any entity in which MRS owns, directly or indirectly, a 50 percent or greater interest”) that are not related to the construction of specified pipeline projects. Several individuals and entities have also been added to OFAC’s Specially Designated Nationals List.

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