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Financial Services Law Insights and Observations

OFAC sanctions Russians engaged in Ukrainian destabilization activities

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

Financial Crimes

On January 20, the U.S. Treasury Department’s Office of Foreign Assets Control announced sanctions pursuant to Executive Order 14024 against four individuals engaged in Russian government-directed influence activities to destabilize Ukraine. OFAC stated that it will continue to take actions, including in partnership with the Ukrainian government, “to undercut Russia’s destabilization efforts.” The designations are the latest actions to target purveyors of Russian disinformation, including similar designations made last April (covered by InfoBytes here). As a result of the sanctions, all property and interests in property of the sanctioned individuals subject to U.S. jurisdiction are blocked and must be reported to OFAC. Additionally, “any entities that are owned, directly or indirectly, 50 percent or more by one or more blocked persons are also blocked.” OFAC noted that its regulations generally prohibit U.S. persons from participating in transactions with the designated persons, which include “the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any blocked person, or the receipt of any contribution or provision of funds, goods or services from any such person.”

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