ARTICLE
10 October 2019

OFAC Sanctions Russian Actors For Attempting To Disrupt 2018 U.S. Midterm Elections

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Cadwalader, Wickersham & Taft LLP

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OFAC designated multiple individuals and entities for their connection to a previously designated Russian-based agency and its financier
United States International Law

OFAC designated multiple individuals and entities for their connection to a previously designated Russian-based agency and its financier, in each case relating to attempts to disrupt the 2018 U.S. midterm elections.

According to OFAC, the Russian-based Internet Research Agency carried out a campaign to influence the 2018 U.S. midterm elections by using fictitious personas on social media to distribute false information. OFAC noted that there was no evidence of the Internet Research Agency or its associated individuals and entities being able to tamper successfully with the election infrastructure. In addition to the designation of seven individuals and four entities under Executive Order 13848, OFAC also identified three aircraft and a yacht as the property of one of the sanctioned persons, financier Yevgeniy Prigozhin.

As a result of OFAC's action, all property and interests in property of the designated individuals and entities, and of any entities that are owned, directly or indirectly, 50 percent or more by them, that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. OFAC regulations also generally forbid all dealings by U.S. persons, and all transactions that occur within or transiting the United States, that involve the property or interests in property of blocked individuals or entities.

The prohibitions applicable to these designated persons includes a ban on any dealings involving the aircraft and yacht identified by OFAC. In addition, the agency warned, non-U.S. persons who service the aircraft and yacht could be subject to sanctions for "facilitating or supporting Prigozhin's nefarious activities." Similarly, certain individuals and entities subject to OFAC's action were previously or concurrently designated under authorities provided by Executive Orders 13694 and 13661, and OFAC warned that non-U.S. persons may be subject to sanctions for knowingly facilitating one or more significant transactions with them.

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