On February 24, 2023, the one-year anniversary of Russia’s invasion of Ukraine, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced the imposition of additional sanctions targeting multiple sectors of the Russian economy, with the aim of further diminishing Russia’s ability to continue its war against Ukraine and to procure the resources to support it.1
One of OFAC’s most significant sanctions actions to date, the new sanctions target Russia’s financial services sector, metals and mining sector, military supply chain, and individuals and entities connected to Russia’s sanctions evasion efforts. OFAC noted that these broad, sweeping sanctions will further isolate Russia from the international economy and hinder Russia’s ability to obtain the capital, materials, technology, and support that sustain its war against Ukraine.
Financial Services Sanctions
Although Russian banks comprising eighty percent of the total Russian banking sector assets are already subject to U.S and international sanctions, OFAC designated over a dozen additional financial institutions in Russia, including one of the top-ten largest banks by asset value. These include:
- Credit Bank of Moscow Public Joint Stock Company
- Joint Stock Company Commercial Bank Lanta Bank
- Public Joint Stock Company Commercial Bank Metallurgical Investment Bank (Metallinvestbank)
- Public Joint Stock Company MTS Bank
- Novosibirsk Social Commercial Bank Levoberezhny Public Joint Company
- Bank Saint-Petersburg Public Joint Stock Company
- Joint Stock Commercial Bank Primorye
- SDM-Bank Public Joint Stock Company
- Public Joint Stock Company Ural Bank for Reconstruction and Development (UBRD)
- Public Joint Stock Company Bank Uralsib
- Bank Zenit Public Joint Stock Company
In conjunction with these designations, OFAC also amended and issued several general licenses permitting certain transactions in connection with these entities:
- General License 8F was amended to include certain of the above-listed financial institutions to the authorization to process certain energy-related transactions.
- General License 13D authorizes U.S. persons, or entities owned or controlled, directly or indirectly, by a U.S. person, to pay taxes, fees, or import duties, and purchase or receive permits, licenses, registrations, or certifications, to the extent such transactions are prohibited by Directive 4 under Executive Order 14024 through 12:01 a.m. eastern daylight time, June 6, 2023.
- General License 60 authorizes the winddown and rejection of transactions involving certain entities blocked on February 24, 2023 through 12:01 a.m. eastern daylight time, May 25, 2023.
- General License 61 authorizes transactions ordinarily incident and necessary to the divestment or transfer, or the facilitation of the divestment or transfer, of debt or equity of certain entities blocked on February 24, 2023 through 12:01 a.m. eastern daylight time, May 25, 2023.
Metals and Mining Sanctions
OFAC issued a new determination pursuant to Section 1(a)(i) of Executive Order 14024 (“Blocking Property With Respect To Specified Harmful Foreign Activities of the Government of the Russian Federation”), which enables the imposition of sanctions on individuals and entities who operate or have operated in the metals and mining sector of the Russian economy.2
Pursuant to this determination, OFAC designated four entities:
- Joint Stock Company Burevestnik Central Scientific Research Institute
- OOO Metallurg-Tulamash
- TPZ-Rondol OOO
This determination complements existing provisions for sanctions against those that operate or have operated in the quantum computing, accounting, trust and corporate formation, management consulting, aerospace, marine, electronics, financial services, technology, and defense and related materiel sectors of the Russian economy.
We will continue to closely monitor developments in this space.
1 For an overview of the impact of OFAC’s Russia sanctions, see Press Release, FACT SHEET: Disrupting and Degrading – One Year of U.S. Sanctions on Russia and Its Enablers, U.S. DEPT. OF THE TREASURY (Feb. 24, 2023), https://home.treasury.gov/news/press-releases/jy1298.
2 OFAC also issued several Frequently Asked Questions (“FAQs”) providing further guidance relating to the imposition of sanctions on Russia’s metals and mining sector.