On April 27, 2023, the US Department of State (“State”) designated Russia’s Federal Security Service (“FSB”) and Iran’s Islamic Revolutionary Guard Corps Intelligence Organization (“IRGC-IO”) pursuant to Executive Order (“EO”) 14078 (Bolstering Efforts To Bring Hostages and Wrongfully Detained United States Nationals Home), with the result that the IRGC-IO has been added to the Specially Designated Nationals and Blocked Persons List (“SDN List”). The IRGC as a whole and FSB were previously designated on the…
On January 25, 2023, the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued an alert to financial institutions regarding potential investments in the US commercial real estate (“CRE”) sector by sanctioned Russian individuals, their family members, and entities through which they act (“Alert”). The Alert complements an earlier alert that FinCEN issued in March 2022, shortly after Russia invaded Ukraine. Our coverage of the March 2022 alert can be found here. In…