The U.S. Treasury Department ("Treasury") Office of Foreign Assets Control ("OFAC") added several Russian entities, individuals and vessels to the Specially Designated Nationals list. In addition, two Treasury officials testified before the Senate Committee on Foreign Relations on the threat posed by Russia's malign activities.
In two separate actions, OFAC designated (i) two Russian entities and six vessels for their role in facilitating the ship-to-ship transfer of refined petroleum products with North Korea-flagged vessels, pursuant to Executive Order 13810, and (ii) two Russian entities and two individuals for procuring underwater equipment and diving systems for Russian government agencies at the direction of a separate sanctioned Russian entity, pursuant to Executive Order 13694.
In testimony before the U.S. Senate Committee on Foreign Relations, Treasury Assistant Secretary for Terrorist Financing Marshall Billingslea underscored that the Treasury "has made countering Russian aggression a top priority." Meanwhile, Treasury Under Secretary for Terrorism and Financial Intelligence Sigal Mandelker testified before the U.S. Senate Committee on Banking, Housing, and Urban Affairs that the Treasury has sanctioned 217 Russian-related individuals and entities for different activities. Ms. Mandelker explained that the Treasury is also deploying other economic authorities, including anti-money laundering measures, enforcement actions and private sector partnerships, among other tools, to disrupt Russia's illicit financial conduct.
Commentary / James Treanor
By imposing sanctions against Russian individuals and entities under separate authorities related to North Korea and malicious cyber-enabled activities, OFAC has highlighted that the Russia sanctions program remains, in the words of Under Secretary Mandelker, "among our most active and impactful." And while the immediate audience for Treasury's message may have been the U.S. Senate – where even tighter Russia-related sanctions are currently under consideration – financial institutions and companies in the shipping, energy, defense, and other industries should also understand that Russia will continue to present elevated sanctions risk for the foreseeable future.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.