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US Imposed Sanctions

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On April 6, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) added two of Russia’s largest banks, Public Joint Stock Company Sberbank of Russia (“Sberbank”) and Joint Stock Company Alfa Bank (“Alfa-Bank”), and their subsidiaries to the Specially Designated Nationals and Blocked Persons List (“SDN List”). OFAC also issued 3 new and 3 amended Russia-related General Licenses, and added several other parties to the SDN List. President Biden also issued…

On February 28, 2022, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued a number of additional sanctions measures against Russia.  The latest measures include the issuance of (i) Russia-related Directive 4 (“Directive 4”), expanding restrictions on Russian state-controlled financial instructions under the April 2021 Executive Order 14024 (“EO 14024”) and (ii) Russia-related General License No. 8A (“GL 8A”), amending and replacing previous General License No. 8.  OFAC also added key Russian state-controlled…

On February 23, 2022, as “another piece of [the US government’s] initial tranche of sanctions in response to Russia’s actions in Ukraine,” the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) designated Nord Stream 2 AG, the Swiss company in charge of building Russia’s Nord Stream 2 gas pipeline, and its German chief executive officer, Matthias Warnig, to OFAC’s List of Specially Designated Nationals and Blocked Persons. The sanctions on Nord Stream 2 follow…

On February 22, 2022, the US Government issued a number of additional sanctions measures against Russia in response to President Putin’s recognition of the independence of the “so-called Donetsk People’s Republic (DNR) and Luhansk People’s Republic in Ukraine (LNR)” and his request to deploy forces to those regions – with President Biden characterizing these developments as “the beginning of a Russian invasion of Ukraine.” The new US sanctions measures build on the comprehensive region-wide sanctions…