OFAC designates 22 Generals and 104 entities for sanctions evasion, Finance-services activity, defence supply and future energy extraction; identifies the architecture, engineering, construction, manufacturing and transportation sectors as sanctionable under Executive Order 14024; bans the export, re-export, sale or supply of US architecture and engineering services to Russia from 18 June 2023; amends Directive 4 to compel US holders of Russian sovereign assets to report them; and blocks additional Russian banks, wealth-management intermediaries, metals-and-mining, technology, electronics, energy-research, drilling-equipment and procurement-network firms, together with the Russian Foreign Intelligence Service, placing all on the SDN List and subjecting their US-linked property and transactions to full blocking.
United States
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Additional banks blocked; metals-and-mining sector determined sanctionable
OFAC invokes Executive Order 14024 to bar over a dozen additional Russian banks, wealth-management intermediaries, sanctions-evasion networks, metals-and-mining, carbon-fibre, aerospace, electronics, technology and defence-industrial firms from all US dealings; designates the metals-and-mining sector itself as sanctionable; blocks associated property and interests
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Wagner sanctions; global network and defence entities blocked
PMC Wagner redesignated as a Significant Transnational Criminal Organization under EO 13581/13863; nine Wagner-linked entities and Generals in China, the CAR and the UAE added to the SDN List; further Russian defence-industrial entities and Putin-associated officials designated under EO 14024, all subject to full blocking sanctions.
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Oil price cap enforcement
OFAC announces that, from 5 February 2023, US persons will be barred from providing maritime-transport and related services for Russian-origin petroleum products unless the cargo is sold at or below a forthcoming price cap.
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Secondary sanctions for significant transactions with Russian gold
The NDAA orders blocking and visa sanctions on any non-US person who knowingly conducts a significant transaction involving the sale, supply, transfer or transport of Russian gold.
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Gold import banned
OFAC applies E.O. 14068 to Russian-origin gold, forbidding its import into the United States unless licensed and exempting only gold that left Russia before the determination
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Ban on accounting, trust-formation and management-consulting services
OFAC forbids US persons to export, re-export, sell or supply accounting, trust- and corporate-formation, and management-consulting services to Russia, and designates those three service sectors under EO 14024 so that any party operating in them can now be subjected to full blocking sanctions.
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Full blocking on Sberbank & Alfa-Bank; limited wind-downs; broad US investment ban in Russia
OFAC designates Sberbank, Alfa-Bank and their respective subsidiaries as SDNs under full blocking sanctions; amended General Licenses 8B, 9B and 10B extend energy-related dealings, debt-and-equity activity and derivative-contract wind-downs involving Alfa-Bank and earlier-listed banks through 24 June or 30 June 2022; a new executive order bars any new US investment in Russia and empowers OFAC to prohibit specified US-origin services and the facilitation of transactions that US persons could not lawfully perform themselves.
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Import bans (seafood, alcohol, diamonds); luxury-goods export and new-investment prohibitions
Executive Order 14068 bars import of Russian fish, seafood, alcoholic beverages, non-industrial diamonds and any other goods later named by Treasury; prohibits export, re-export, sale or supply of US luxury goods to Russia; forbids new US investment in any Russian sectors Treasury may designate; bans export or supply of US-dollar banknotes to the Russian government or Generals in Russia; and blocks US-person approval, financing, facilitation or guarantee of transactions by foreign parties that would breach these prohibitions if undertaken by a US person.
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Central-Bank transaction ban
Directive 4 bars US persons from any transaction with Russia’s Central Bank, National Wealth Fund or Ministry of Finance; three additional entities and one General are placed on the SDN List