UPDATE: This client alert was updated on April 11, 2022 to include a description of additional actions announced by the Biden administration in response to Russia's ongoing invasion of Ukraine. Since our prior update, President Biden signed an Executive Order prohibiting new investment in Russia by U.S. persons (described in section XIII, below). OFAC also announced the designation of Sberbank and Alfa-Bank, as well as several of their respective subsidiaries, in a major escalation of sanctions on Russia's financial sector (described in sections I and II, below). In addition, OFAC designated family members of President Putin and Foreign Minister Sergey Lavrov, and numerous government officials (described in section IX, below), as well as major state-owned enterprises and their subsidiaries (described in section XII, below).

The Biden administration has imposed sweeping new sanctions on Russia in response to Russia's invasion of Ukraine. The sanctions against Russian targets build on the imposition of comprehensive sanctions on the Donetsk and Luhansk regions of Ukraine on February 21, 2022, as detailed in our prior client alert.

This alert summarizes the full package of sanctions announced to date by the Biden administration in response to Russia's invasion of Ukraine:

  • the designation of major Russian financial institutions, including JSC Alfa-Bank ("Alfa-Bank"), VTB Bank PJSC ("VTB"), Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank ("VEB"), and others;
  • expanded prohibitions on dealing in Russian sovereign debt;
  • the evolution of sanctions on PJSC Sberbank ("Sberbank");
  • certain debt and equity prohibitions against identified entities;
  • prohibition on engaging in any transaction involving the Russian Central Bank, the National Wealth Fund, or the Ministry of Finance;
  • designation of Nord Stream 2 AG and its chief executive officer;
  • the designation of individuals with close ties to President Putin;
  • prohibitions on the importation of Russian energy and new investment in the Russian energy sector;
  • prohibitions on the importation of Russian-origin fish, seafood and preparations thereof, alcoholic beverages, and non-industrial diamonds;
  • prohibitions on the exportation of certain luxury goods;
  • prohibitions on the exportation of U.S.-dollar denominated banknotes;
  • designation of major entities operating in specified sectors of the Russian economy; and
  • prohibition on new investment in Russia.

President Biden also announced new export control requirements under the Export Administration Regulations, which impose license requirements on certain exports to Russia. Please see our client alert, Sweeping Export Controls on Russia and Belarus Reach New Heights: Novel Foreign Direct Product Rules and Expanded Licensing Requirements," for more information.

At the same time as imposing sanctions on Russia, President Biden announced on February 24, 2022, a new tranche of sanctions targeting the Lukashenka regime in Belarus, with the designation of 24 Belarusian persons, including state-owned banks and the defense and security industries, in response to Belarus's facilitation of Russia's invasion of Ukraine. OFAC's announcement listing the Belarusian designations is available here.

To read the full article, please click here.

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.