Our clients across every industry are asking us what we expect to happen with the Russia sanctions under the Trump Administration. Will President Trump relax the Russia sanctions, and if so, when? All or only some of them? Or will President Trump ramp up the Russia sanctions to put pressure on Russia to agree to a peace deal with Ukraine? Will Congress get involved, and how? We will be tackling these questions and more in our webinar this Wednesday, March 19. We hope you can join us – additional information and the registration link are available here.
With so many possibilities on the horizon, it can be easy to lack clarity on the current state of play. What has the Trump Administration actually done – or not done – so far? When we look back at the first two months of the Trump Administration, this is what we see:
- No Sanctions Removed: The Trump Administration has not removed or relaxed any of the US sanctions or export controls against Russia.
- No New Sanctions on Anniversary of Invasion: For the first time since the invasion in 2022, the United States did not impose new sanctions against Russia around the anniversary of the invasion on February 24.
- Biden Energy Sector Sanctions Allowed to Go Into Effect: The Trump Administration allowed the energy sector sanctions imposed at the end of the Biden Administration on January 10 to go into effect. This included a prohibition on US Persons providing petroleum services to anyone in Russia, which had come with a delayed effective date of February 27. The January 10 measures also included a series of wind-down general licenses that expired on February 27 and March 12. See our blog post on these January 10 sanctions here.
- Ukraine National Emergency Continued for Another Year: As reported in the Federal Register on February 27, President Trump continued the national emergency with respect to Ukraine for another year, until March 6, 2026. This national emergency was first declared by President Obama in 2014 to address threats to the democracy and sovereignty of Ukraine. This national emergency underpins a large number of sanctions against individuals and entities in Russia under Executive Order 13662 following Russia’s annexation of Crimea. (Most of the post-2022 sanctions against Russia were based on a different national emergency declared by President Biden in 2021 in Executive Order 14024. However, in its final weeks, the outgoing Biden Administration imposed a number of sanctions under both EO 14024 and EO 13662 in an attempt to make the sanctions more difficult to remove later – see our blog post on the Biden Administration’s final Russia sanctions imposed on January 10 here and January 15 here.)
- No New SDNs: The Trump Office of Foreign Assets Control (“OFAC“) has not designated any new parties on its List of Specially Designated Nationals (“SDN List“) under the main Russia sanctions authorities, i.e., EO 14024 and EO 13662. However:
- In a coordinated action with the UK and Australia, on February 11, OFAC added a Russian cybercrime operation to the SDN List. While this designation was made under a cybersecurity sanctions program and not the Russia sanctions, this designation of Russian parties was noteworthy given the broader discussions about Russia and cybersecurity happening in the public sphere. See our blog post on this development here.
- We also noticed that when OFAC added several members of Ansarallah (the Houthis) to the SDN List on March 5, the press release highlighted that these individuals had negotiated Houthi weapons procurement from Russia. The press release also noted that OFAC was designating a Houthi-affiliated operative and his company that had recruited Yemeni civilians to fight on behalf of Russia in Ukraine. The press release goes into some detail on these allegations, referencing the word Russia more than 20 times and even naming President Putin once.
- A Mixed Bag on Enforcement:
- Task Force KleptoCapture, one of the Biden era enforcement initiatives, has been disbanded. This was announced in a memo issued by US Attorney General Pam Bondi on February 5. This was a task force within the US Department of Justice focused on enforcing the sanctions against Russian oligarchs. This was the task force behind many of the high-profile asset seizures that were widely reported in the press, such as luxury yachts.
- Still, criminal enforcement activity has continued. There has been movement in several cases involving potential violations of export controls prohibited exports of aircraft parts to Russia, including this indictment on February 13 and this sentencing on February 21.
