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SSI List

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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.

On October 31, 2017, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) amended and reissued Directive 4 of the Ukraine/Russia-related sectoral sanctions (“Directive 4”), which targets the Russian energy sector, and updated its guidance regarding the implementation of Ukraine/Russia-related sanctions.  OFAC’s amendment and reissuance of Directive 4 was expected pursuant to Section 223(d) of Title II of the Countering America’s Adversaries Through Sanctions Act (“CAATSA” see our previous blog post on CAATSA here).  Also under CAATSA, Directive 1 and Directive 2 were amended and reissued on September 29, 2017 (see our previous blog post here).  OFAC originally published Directive 4 in September of 2014, pursuant to Executive Order 13662.  In conjunction with OFAC’s guidance, the US Department of State (“State Department”) also published guidance regarding CAATSA Sections 225 and 232.

On September 29, 2017, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) amended and reissued Directive 1 and Directive 2 implementing US sectoral sanctions targeting Russia pursuant to the Countering America’s Adversaries Through Sanctions Act (“CAATSA”). The maturity of prohibited “new debt” under Directive 1 will be reduced to 14 days (from 30 days) and the maturity of prohibited “new debt” under Directive 2 will be reduced to 60 days (from 90 days).

On June 20, 2017, the US Office of Foreign Assets Control (“OFAC”) announced that it had added 38 individuals and entities to the Specially Designated Nationals and Blocked Persons List (“SDN List”) and 20 entities to the Sectoral Sanctions Identification List (“SSI List”) under US sanctions targeting Russia and Crimea.  On June 21, 2017, the US Bureau of Industry and Security (“BIS”) also announced that it would add some of these SDN entities to the Entity List.