OFAC designated seven Russian government officials in response to the August 2020 poisoning and January 2021 imprisonment of opposition leader Aleksey Navalny.

According to OFAC, the Novichok nerve agent, which European laboratories identified as responsible for Mr. Navalny's poisoning, has only ever been utilized as a chemical weapon by Russia, and is only accessible to Russian state authorities.

Pursuant to Executive Order ("EO") 13661 ("Blocking Property of Additional Persons Contributing to the Situation in Ukraine"), OFAC sanctioned the following individuals for serving as officials of the Russian government:

  • Federal Security Service ("FSB") Director Aleksandr Bortnikov;
  • Chief of the Presidential Policy Directorate Andrei Yarin;
  • First Deputy Chief of Staff of the Presidential Executive Office Sergei Kiriyenko;
  • Deputy Minister of Defense Aleksey Krivoruchko;
  • Deputy Minister of Defense Pavel Popov;
  • Federal Penitentiary Service Director Alexander Kalashnikov; and
  • Prosecutor General Igor Krasnov.

OFAC also designated FSB Director Bortnikov under EO 13382 ("Blocking Property of Weapons of Mass Destruction Proliferators and Their Supporters") for acting on behalf of the FSB.

The State Department - also under EO 13382 - sanctioned the FSB, the Main Intelligence Directorate ("GRU"), and GRU officers Alexander Mishkin and Anatoliy Chepiga, as well as three Russian scientific centers, for having engaged in activities that contribute to the proliferation of weapons of mass destruction, in this case Novichok.

Additionally, the State Department added six entities connected to the Russian defense or intelligence sectors to the Countering America's Adversaries Through Sanctions Act Section 231 List of Specified Persons, stating that these designations are in response to "the malign activities in which Russia's defense sector engages - especially with respect to its chemical weapons program." Persons who engage in a "significant transaction" with any of the entities named to the Section 231 List are subject to the imposition of secondary sanctions.

To reflect the imposition of these new sanctions, OFAC issued an updated General License 1B, which authorizes certain transactions with the FSB, (see three related FAQs: 501502503.)

Primary Sources

  1. Treasury Press Release: Treasury Sanctions Russian Officials in Response to the Novichok Poisoning of Aleksey Navalny
  2. U.S. Department of State Press Release: Imposing Sanctions on Russia for the Poisoning and Imprisonment of Aleksey Navalny
  3. U.S. Department of State Fact Sheet: Imposing Sanctions on Russia for the Poisoning and Imprisonment of Aleksey Navalny
  4. OFAC General License 1B: Authorizing Certain Transactions with the Federal Security Service
  5. OFAC FAQ: Cyber-related Sanctions - 501
  6. OFAC FAQ: Cyber-related Sanctions - 502
  7. OFAC FAQ: Cyber-related Sanctions - 503

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