On November 2, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated 130 new Russian entities and individuals that OFAC identified as supporting Russia’s war in Ukraine by “providing Russia with much-needed technology and equipment from third countries.” On the same day, the U.S. Department of State issued nearly 100 sanctions targeting Russia’s future energy production and revenue, metals and mining sector, defense procurement, and those involved in supporting the Russian government’s war effort and other activities.
Sanctions Targeting Russia’s International Supply Chains
Per OFAC, Russia has continued to exploit otherwise legitimate economic relationships with the People’s Republic of China (“China”), Türkiye, and the United Arab Emirates (“UAE”), which have become hubs for exporting, reexporting, and transshipping to Russian foreign-made technology and equipment. OFAC noted that they are continuing to work with partners to prevent further Russian sanctions evasion and export control violations through their jurisdictions, and recent actions, particularly by the UAE, are encouraging.
According to OFAC, entities based in China, Türkiye, and the UAE continue to send high-priority dual-use goods to Russia. These dual-use goods include critical components that Russia relies on for its weapons systems. As a response to this, OFAC designated multiple individuals and entities based in these countries.
Sanctions Aimed at Russia’s Domestic Industrial Base
OFAC designated a wide array of Russia-based industrial firms that produce, import, distribute, and repair industrial machinery, machine tools, spare parts, additive manufacturing equipment, ball bearings, and other industrial equipment and materials. Designated entities also manufacture and distribute products for air navigations and meteorology, industrial laser equipment, drilling tools and equipment, valves and automatic control devices, carbon composite materials, industrial automation systems, electric motors and generators, and laser metal surfacing technology.
OFAC also designated multiple Russian nationals connected with various designated Russian entities.
Advanced Technology Sanctions
OFAC designated multiple Russia-based entities and individuals that finance, research, develop, or import advanced technology, including Russia’s finance and technology conglomerate Sistema Public Joint Stock Financial Corporation (“Sistema”). Along with Sistema, OFAC designated three subsidiaries pursuant to Executive Order (“EO”) 14024 for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Sistema:
- Luxembourg-based East West United Bank SA
- Singapore-based Sistema Asia PTE LTD
- Russia-based Sistema Smarttekh
OFAC also designated multiple other Russian entities that operate or have operated in the electronics sector of the Russian Federation economy, including manufacturers and suppliers of computes and related devices, radio electronics and electronic printed circuits, specialty gases for the semiconductor industry, semiconductors, microelectronics, and other related items.
Targeting Russia’s Financial Services Sector
Finally, OFAC designated seven Russia-based banks, an executive of one of those banks, and one Russia-based financial infrastructure entity. These banks include Public Joint Stock Company Saint Petersburg Exchange, Commercial Bank Absolut Bank PAO, Blanc Bank Limited Liability Company, Home Credit & Finance Bank Limited Liability Company, Joint Stock Company Post Bank, Publichnoe Aktsionernoe Obshchestvo Kommercheski Bank Russki Regionalny Bank, Joint Stock Company Russian Regional Development Bank, and Joint Stock Company Russian Standard Bank.
As a result of OFAC’s actions, all property and interests in property of the persons above that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. In addition, any entities that are owned, directly or indirectly, 50 percent or more by one or more blocked persons are also blocked. All transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or blocked persons are prohibited unless authorized by a general or specific license issued by OFAC, or exempt. These prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any blocked person and the receipt of any contribution or provision of funds, goods, or services from any such person.
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