On May 22, 2018, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued General License 15 (“GL 15”) and General License 12C (“GL 12C”), replacing and superseding General License 12B (“GL 12B”). Please see our prior blog posts concerning (i) the designation of certain Russian parties here and (ii) the issuance of GL 12B here.
On April 6, 2018, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced new sanctions measures designating as Specially Designated Nationals (“SDNs“) seven Russian oligarchs and 17 Russian government officials previously identified in a report issued pursuant to Section 241 of the Countering America’s Adversaries Through Sanctions Act (“CAATSA“; see our previous blog post on this report here) under the authority of Executive Orders 13661 and 13662, pertaining to destabilizing activities by Russia in Ukraine. OFAC also designated 12 entities owned or controlled by those newly designated oligarchs and, under the separate authority of Executive Order 13582, pertaining to support for the Government of Syria, a Russian weapons-trading company and related bank. A complete list of the designated individuals and entities is available here.
On March 15, 2018, the US Office of Foreign Assets Control (“OFAC”) added 14 individuals and one entity, the so-called Russian “troll farm” Internet Research Agency LLC (“IRA”), to the Specially Designated Nationals and Blocked Persons List (“SDN List”). OFAC announced a total of 24 designations against persons pursuant to Executive Order (“EO”) 13694 (issued April 1, 2015 and amended December 29, 2016), which is the “Cyber EO” that targets certain “malicious cyber-enabled activities,” and pursuant to Section 224 of the Countering America’s Adversaries Through Sanctions Act (“CAATSA”) , which specifically targets cyber actors who operate on behalf of the Russian government. Nine of the 24 persons identified in OFAC’s announcement were already included on the SDN List. Please see our prior blog post on CAATSA here and prior blog posts on the Cyber EO and its amendment here, here, and here.
On January 29, 2018, the US Treasury Department (“Treasury”) delivered five reports to Congress, as required under the Countering America’s Adversaries Through Sanctions Act (“CAATSA”). Please see our prior blog post on CAATSA here. Among these reports was a list identifying Russian senior political figures, oligarchs, and parastatal entities pursuant to CAATSA Section 241. This report was released during the same week that other CAATSA sanctions targeting Russia have gone into effect.