On August 20, 2021, President Joseph R. Biden signed an Executive Order ("EO") blocking all property and interests in property of individuals and entities identified by the Secretary of State to be involved in Russian energy export pipelines. Additionally, the Secretary of State identified in a report to Congress one Russian vessel and two Russian individuals involved in the Nord Stream 2 pipeline, indicating that the vessel and individuals would be targeted by U.S. economic sanctions.
The August 20th EO is intended to (i) expand on the April 15th EO that blocked all property and interests in property of any person determined to have engaged in "specified harmful foreign activities" on behalf of the Government of the Russian Federation and (ii) respond to developments in Russian energy pipeline projects, including the Nord Stream 2 pipeline, that aim to expand Russia's influence on Europe's energy infrastructure.
In a related action, OFAC issued General License ("GL") No. 1A to supersede GL No. 1, authorizing certain transactions and activities prohibited by the August 20th EO that do not relate to the construction of the Nord Stream 2 pipeline. In connection with this action, OFAC (i) outlined the authority of GL No. 1A in updated FAQ 894 and (ii) explained in FAQ 921 the purpose and impact of the August 20th EO.
In addition, OFAC issued FAQs 919 and 920, which explain the impact of sanctions imposed by the U.S. Department of State (under the Chemical and Biological Weapons Control and Warfare Act of 1991) in response to the 2020 poisoning of opposition leader Aleksey Navalny.
Finally, OFAC made related updates to its SDN List.
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