OFAC Points Sweeping Sanctions to Mark One-12 months Anniversary of Russia’s Invasion of Ukraine

On Friday, February 24, 2023, the US Treasury Division’s Workplace of International Belongings Management (“OFAC”) issued new sanctions towards people and entities working in Russia and towards these aiding with Russia’s struggle efforts in Ukraine. Together with OFAC’s extra sanctions, BIS additionally carried out extra export management measures and added 86 recognized supporters of the Russian protection sector to the Entity Checklist. For a full dialogue of the export management and Entity Checklist additions see our separate weblog put up. The White Home additionally issued a press release stating that starting March 10, there will probably be a 200% tariff on Russian aluminum coming into the US. For extra data on that announcement and its implications, see our separate weblog put up.

OFAC’s newest spherical of sanctions targets a number of Russian industries together with, mining and metals, the monetary sector, navy provide chain, the aerospace trade, and the know-how and electronics industries. The sanctions additionally spotlight the US’s use of secondary sanctions to sanction people and entities aiding Russia’s struggle efforts, aiding with sanctions evasion, and the backfilling of needed elements, parts, and supplies.

OFAC Sanctions

Mining and Metals Sector Willpower and Designations

OFAC issued a brand new Willpower pursuant to Govt Order 14024 (“E.O. 14024”) which authorizes OFAC to impose blocking sanctions on any particular person working within the “metals and mining sector of the Russian Federation economic system”. This Willpower is much like current Determinations and different Govt Orders which have approved OFAC to impose blocking sanctions on individuals working in numerous sectors of Russia’s economic system together with: quantum computing, accounting, belief and company formation, administration consulting, aerospace, marine, electronics, monetary providers, know-how, and protection and associated materials sectors of Russia.

Pursuant to this new directive, OFAC added the next entities to the Specifically Designated Nationals and Blocked Individuals Checklist (“SDN Checklist”) as individuals working within the mining and metals sector of the Russian economic system:

• Joint Inventory Firm Burevestnik Central Scientific Analysis Institute
• OOO Metallurg-Tulamash
• TPZ-Rondol OOO
• Mtsenskprokat

OFAC additionally revealed Continuously Requested Questions (“FAQs”) associated to the brand new Willpower one in all which outlined the time period “metals and mining sector of the Russian Federation economic system” to incorporate “any act, course of, or trade of extracting, on the floor or underground, ores, coal, treasured stones, or another minerals or geological supplies within the Russian Federation, or any act of procuring, processing, manufacturing, or refining such geological supplies, or transporting them to, from, or throughout the Russian Federation”.  Nevertheless, these FAQs additionally suggested that OFAC won’t goal individuals for sanctions designations pursuant to this new Directive when these individuals’ provide of products and providers to the “metals and mining sector of the Russian Federation economic system” is “solely for the security and care of personnel, safety of human life, prevention of accidents or accidents, upkeep or restore essential to keep away from environmental or different vital injury, or actions associated to environmental mitigation or remediation”.

Monetary Companies Sector Designations

OFAC additionally used pre-existing E.O. 14024 Determinations to impose SDN Checklist designations on a number of banks and different entities working within the monetary sector. These entities embrace: