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Financial Services Law Insights and Observations

OFAC sanctions Russian human rights abusers

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

Financial Crimes

On March 3, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions, pursuant to Executive Order (E.O.) 13818, against three individuals involved in serious human rights abuses against a prominent Russian human rights defender. The designations are complemented by visa restrictions imposed by the Department of State against two of the individuals and their families. The Department of State also concurrently designated three other individuals pursuant to E.O. 14024 “for being or having been leaders, officials, senior executive officers, or members of the board of directors of the Government of the Russian Federation.” As a result of the sanctions, all property and interests in property belonging to the sanctioned persons that are in the U.S. or in the possession or control of U.S. persons are blocked and must be reported to OFAC. Additionally, “any entities that are owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked.” U.S. persons are also generally prohibited from engaging in any dealings involving the property or interests in property of blocked or designated persons unless authorized by a general or specific license issued by OFAC, or exempt.