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Monitoring of the USA Sanctions

3 ноября 2023

Nadmitov, Ivanov & Partners Law Firm prepared an overview of the sanctions imposed on Russian individuals and organizations by the United States of America in connection with the crisis around Ukraine.

3 November 2023

US imposes new sanctions against companies and individuals, targeting Russia’s energy capabilities and sanctions evasion. The sanctions imposed target third-party companies and individuals alleged to assist Russia in procuring equipment needed for military purposes, including suppliers and shippers.

The new measures include sanctions against the Russian energy and mining sectors, and lists more than 200 names around the world facing financial and other restrictions. The purpose of these restrictions is primarily aimed at stopping Russia from sidestepping existing sanctions against its defence industry. It also included measures to clamp down on sanctions evasion in the United Arab Emirates, Turkey and China.

The restrictions have extended to a number of Russian banks, including Russian Standard Bank, Absolut Bank, Bank Home Credit, Post Bank, Russian regional development bank, Russian Regional Bank and Blanc Bank. AFK Sistema PAO, Arctic LNG 2, St. Petersburg Stock Exchange, entities of the Gazprom Neft group and Bauman Moscow State Technical University are under sanctions too.

In total, thirty Russian individuals and almost two hundred companies were hit by restrictions.

15 September 2023

OFAC included Ak Bars Bank to the sanctions list.

In total, 20 individuals and several dozen companies were included in the SDN list.

Among them: Avtodor, AvtoVAZ, Moskvich plant, Russian Copper Company, Sinco-Bank, Kirov Plant and Transmashholding. Among the individuals are ex-president of Transmashholding Andrey Bokarev, head of UMMC Iskandar Makhmudov and his son Jahangir, founder of the Russian Copper Company (RMK) Igor Altushkin

11 August 2023

On August 11, 2023, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) imposed new sanctions on Russian individuals and companies.

In a press release, the U.S. Treasury Department announced that the sanctions targeted representatives of one of the largest financial conglomerates in Russia, who are members of the supervisory board of the Alfa Group consortium:

  • Petr Aven, former board member and shareholder of Alfa-Bank.
  • Mikhail Fridman, co-founder of Alfa Group, former board member and shareholder of Alfa-Bank.
  • German Khan, co-founder of Alfa Group and former shareholder of Alfa-Bank.
  • Alexey Kuzmichev, co-founder of Alfa Group and former shareholder of Alfa-Bank.

Additionally, for the first time, the Russian Union of Industrialists and Entrepreneurs (RSPP) - the largest organization in Russia that unites business structures - has been included in the sanctions lists.

It is worth noting that the founders of Alfa Group were previously included in the sanction lists of Australia, Canada, the European Union, and the United Kingdom, which led to Petr Aven and Mikhail Fridman leaving the board of directors of Alfa-Bank, and German Khan and Alexey Kuzmichev exiting the bank's list of shareholders.

20 July 2023

On July 20, 2023, OFAC announced the expansion of the sanctions list and added the following individuals:

  • Kudrin A.S. - Former Minister of Finance of the Russian Federation and former Chairman of the Accounts Chamber of the Russian Federation;
  • Korolev S.B. - First Deputy Director of the Federal Security Service (FSB) of the Russian Federation;
  • Gornin L.V. - Deputy Minister of Finance;
  • Khersoncev A.I. - Deputy Minister of Economy;
  • Torosov I.E. - Deputy Minister of Economy;
  • Osmakov V.S. - Deputy Minister of Industry;
  • Snikkars P.N. - Deputy Minister of Energy;
  • Sorokin P.Yu. - Deputy Minister of Energy.

Tinkoff, Yunistrim, Loko, and Petersburg Social Commercial Bank were also included in the US sanctions list (SDN List).


12 April 2023

On 12 April 2023, the US Office of Foreign Assets Control (OFAC) placed a number of entities and individuals from Russia, Hungary, and Cyprus on the sanctions list. The list includes 34 individuals and several dozen legal entities from Russia, individual citizens of Hungary and Cyprus.

Among the individuals who fell under the sanctions are the former Minister of Transport and General Director of the State Transport Leasing Company Evgeny Ditrikh, the president of Rusatom Overseas JSC Evgeny Pakermanov. The list includes the following companies: Metalloinvest and its constituents Mikhailovsky GOK, Lebedinsky GOK, OEMK, Megafon, Rusatom Overseas.

The International Investment Bank (IIB) in Hungary, its head Nikolai Kosov and deputy chairmen of the board Georgy Potapov and Imre Laszlotsky, are also included in the sanctions list. 

26 February 2023

The US Department of Commerce banned the supply of smartphones over $300 to Belarus and Russia. Under the new export restrictions: fans (wall, floor, rooftop), wholesale air conditioners worth over $, refrigerators over $750, dishwashers, electronic scales over $100, printers over $300, vacuum cleaners with built-in electric motor over $100, microwave ovens for home use, household coffee machines, electric toasters, sound recording and reproducing equipment.


24 February 2023

The US Treasury imposed sanctions on 22 individuals and 83 legal entities, including 11 Russian banks. In particular, Credit Bank of Moscow, Urasib Bank, MTS Bank, Saint Petersburg Bank, Zenit Bank and a number of other banks.

In addition, sanctions include a 200% duty on the import of aluminum and aluminum products from Russia from March 10.

The sanctions list also includes the heads of 47 regions of the Russian Federation, 9 ministers, including the heads of the Ministry of Culture, the Ministry of Emergency Situations, the Ministry of Sports, the Ministry of Energy and the Ministry of Digital Development, Tatyana Golikova and her husband Viktor Khristenko, host Olga Skabeeva, and 1219 Russian military.

76 organizations are blacklisted by the US Department of Commerce, including the Federal Service for Military-Technical Cooperation of the Russian Federation, Megafon, the Skolkovo Technopark and the Skolkovo Institute of Science and Technology (Skoltech).

In addition, the investment management company Veles Capital and related firms, as well as the financial company CONFIDERI Pte Ltd, fell under the sanctions.


15 December 2022

OFAC announces the inclusion of the following individuals on the SDN List:

·         Vladimir Potanin and his family;

·         Rosbank;

·         Interros Company (owned by Vladimir Potanin);

·         a number of companies identified as “related to VTB”: Embassy Development, ITC Consultants, Citibike, VTB Development, VTB Commercial Financing, VTB Infrastructure Investments, Megacom, Kordeks, Debt Center”, VTB Project, SG-Development, VTB Commodities, VTB Real Estate and VTB Leasing.

2 August 2022

- OFAC announces the inclusion of the following persons in the SDN List:

·         Viktor Rashnikov, Magnitogorsk Iron and Steel Works;

·         Grigory and Andrey Guryev, co-owners of Phosagro;

·         Andrey Melnichenko, a former co-owner of SUEK and EuroChem;

·         Alexander Ponomarenko, a co-owner of Sheremetyevo Airport;

·         Dmitry Pumpyansky, a founder of the Pipe Metallurgical Company. Together with PJSC Magnitogorsk Iron and Steel Works, a number of structures affiliated with it fell under the US sanctions, including the Turkish plant MMK, PJSC STLC and its subsidiaries (including SPV, which is an issuer of Eurobonds - GTLK Europe Capital DAC), as well as Skoltech, Skolkovo Technopark and the Skolkovo Foundation.

Fertilizer producers PhosAgro and EuroChem, as well as Sheremetyevo airport, are unaffected by the blocking sanctions imposed on businessmen associated with them.

Source: https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220802


14 June 2022

- The United States extended the license for energy financing operations with sanctions Russian structures from June 24 to December 5, 2022. The license allows energy financing transactions with Sberbank, VTB, Otkritie Bank, Alfa-Bank, Sovcombank or their subsidiaries, as well as with VEB and the Central Bank of the Russian Federation. The concept of "energy" for the purposes of this license includes both the extraction/transportation/liquefaction of oil or gas, and the production of other energy sources, including coal, uranium and renewable energy sources.

2 June 2022

- Under the new blocking US sanctions: Chairman of the Board of Directors of Severstal Alexei Mordashov and members of his family, Chairman of the Board of Directors of the company "Kievskaya Ploshchad" God Nisanov and First Deputy CEO of PhosAgro Evgeny Novitsky. Sanctions have also been imposed against PJSC Severstal itself, Severgroup and the gold mining company Nord Gold. The holding company Ak Bars and OOO Gazprom Neft Shelf are also fall under the US sanctions list.

8 May 2022

- The U.S. Office of Foreign Assets Control (OFAC) issued a Determination that extended a ban on the provision of the following category of services: accounting services, the establishment of trusts and organizations, management consulting to persons located in the territory of the Russian Federation.

The Determination excludes from the prohibition:

·         any services of an organization located in the Russian Federation that is directly or indirectly owned or controlled by a US person;

·         any services in connection with the liquidation or disposal of an entity located in the Russian Federation that is not owned or controlled, directly or indirectly, by a Russian entity.

Source: https://home.treasury.gov/system/files/126/determination_05082022_eo14024.pdf


20 April 2022

- The US Treasury imposed sanctions against 40 Russian legal entities, including Transcapitalbank, which acts as a settlement center for the Hello payment system (with two licenses to complete transactions with TCB), as well as 29 individuals, including members of the board and supervisory board of Otkritie FC Bank PJSC , including Chairman of the Board Mikhail Zadornov and Deputy Chairman of the Central Bank of Russia Ksenia Yudaeva (https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220420).

7 April 2022

- The United States excluded from the sanctions list against Russia telecommunications equipment, software and technologies related to Internet messaging, such as instant messaging, video conferencing, chat and email, social networks, sharing photos, movies and documents, browsing the web pages, blogging, web hosting and domain name registration services (https://home.treasury.gov/system/files/126/russia_gl25.pdf).

6 April 2022

- The United States imposed blocking sanctions against Sberbank and Alfa-Bank, which means a complete blocking of bank assets in the country, a ban on US citizens and companies from conducting any transactions with them. The sanctions list included most of the companies of the Sberbank group of entities and a number of its subsidiaries, including in Kazakhstan and Europe, as well as most of the companies of the Alfa-Bank group of entities, including even tankers that belong to the Alfa-Bank leasing company. OFAC simultaneously issued 6 licenses: American citizens and structures will have to complete all transactions with Sberbank and its subsidiaries by April 13, 2022, with Alfa Bank - by May 6. Transactions required to complete the work of Sberbank CIB USA, including payment of wages and severance pay, must be completed by June 7.

The US Treasury license provides that until June 24, 2022, Sberbank and Alfa-Bank, as well as structures already under sanctions (VEB, Sovcombank, VTB, Otkritie, and the Central Bank) will be allowed operations related to servicing transactions in the energy sector. Until May 25, US citizens will have to sell shares in the capital and debt obligations of Sberbank (moreover, the transaction must be made with a citizen of another country), in the case of Alfa Bank, such a license is valid until June 30.

Source: https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220406

- There was also a ban on:

·         new investments in the Russian Federation by a person from the United States, regardless of its location;

·         export, re-export, sale or supply, directly or indirectly, from the United States or by a person of the United States, regardless of its location, of any category of services, as may be determined by the US Secretary of the Treasury in consultation with the US Secretary of State, to any person located in the Russian Federation;

·         any approval, financing, assistance or guarantee by a person from the United States, regardless of location of a transaction with a foreign person.5 апреля 2022 г.

- The United States suspended the exchange of tax information with the Russian Federation (https://www.reuters.com/world/us/exclusive-us-suspends-tax-information-exchange-with-russian-authori...).

Darknet Hydra and cryptocurrency exchange Garantex Europe OU are included in the US sanctions list.

17 March 2022

- The House of Representatives of the US Congress almost unanimously passed the bill announced by the President of the United States on the suspension of normal trade relations with Russia and Belarus (https://www.congress.gov/bill/117th-congress/house-bill/7108/text?q=%7B%22search%22%3A%5B%22chamberA...:

Russia is deprived of (standard for most countries of the world) most favored nation treatment in trade with the United States, which will allow the introduction of additional prohibitive duties on Russian imports;

The US trade representative is obliged to raise the issue of Russia's exclusion from the organization and the suspension of Belarus' application to the WTO.

The effect of the bill will be manifested in the supply of aluminum, timber and fertilizers from Russia.

15 March 2022

- The US State Department announced sanctions against 11 representatives of the Russian defense sector: the head of the National Guard Viktor Zolotov, the director of the FSMTC Dmitry Shugaev, the general director of Rosoboronexport Alexander Mikheev, as well as the deputy heads of the Russian Defense Ministry Alexei Krivoruchko, Timur Ivanov, Yunus-Bek Evkurov, Dmitry Bulgakov, Yuri Sadovenko, Nikolai Pankov, Ruslan Tsalikov and Gennady Zhidko.

11 March 2022

- The US Department of the Treasury published a guide explaining how cryptocurrency should not be used to circumvent economic sanctions imposed on Russia for its "invasion of Ukraine". The Department clarifies that U.S. persons, including virtual currency exchanges, virtual wallet hosts, and other service providers, such as those that provide nested services for foreign exchanges, are prohibited from participating in prohibited transactions (including virtual currency transactions in which blocked persons) or assist them. US citizens are also prohibited from participating in or facilitating prohibited transactions, including virtual currency transactions involving the Central Bank of the Russian Federation, the National Welfare Fund of the Russian Federation or the Ministry of Finance of the Russian Federation. US financial institutions are also prohibited from processing transactions, including virtual currency transactions.

- the US President Joe Biden signed an Executive Order prohibiting certain types of exports, imports and new investments in relation to the Russian Federation (https://home.treasury.gov/system/files/126/russia_eo_20220311.pdf). As such, the following are highlighted:

·         a ban on the import of fish, seafood, alcoholic beverages, non-industrial diamonds, any other goods of Russian origin, as may be determined by the Minister of Finance in consultation with the Secretary of State and the Minister of Commerce;

·         a prohibition of the export, re-export, sale or supply (directly or indirectly) from the United States or by a person of the United States, wherever located, of luxury goods and any other goods as may be determined by the Secretary of Commerce in consultation with the Secretary of State and the Minister Finance, to any person located in the Russian Federation;

·         a ban on new investments in any sector of the economy of the Russian Federation;

·         a prohibition of the export, re-export, sale or supply (directly or indirectly) from the United States, or by a person of the United States, wherever located, of banknotes denominated in US dollars to the Government of the Russian Federation or to any person located in the Russian Federation.

8 March 2022

- The import into the United States of the following nomenclatures of goods and raw materials of Russian origin is prohibited: crude oil, gasoline, fuel, petroleum products and products of their distillation, liquefied natural gas, coal and coal products (according to General License No. 16 (https://home.treasury. gov/system/files/126/russia_gl16.pdf). All of the above can be delivered to Russia until 12:00 on April 22, 2022 in pursuance of agreements and contracts concluded before March 8, 2022.

- US persons are prohibited from investing in the Russian energy sector. The prohibitions of the new order do not apply to the US Government and the UN, including its specialized agencies, programs, funds and organizations (https://home.treasury.gov/system/files/126/eo_prohibitions_imports_investments.pdf).

5 March 2022

- The inclusion of Alisher Usmanov in the SDN list is accompanied by the general license No. 15 - non-application of the 50%+ rule to the companies of Alisher Burkhanovich. All companies in which Usmanov owns 50% or more are not subject to the prohibitions and restrictions codified in Regulation No. 587, their assets are not blocked, write-offs from the accounts of such companies are not prohibited.

4 March 2022

- The United States imposed personal sanctions against the sons of Chemezov, the daughter of Dugin, Dmitry Peskov, the Prigozhin family, the family of Boris Rotenberg, Igor Shuvalov and his family, Alisher Usmanov, Nikolai Tokarev and his family.

- Sanctions imposed against aircraft manufacturing enterprises of the Russian Federation, including the Irkutsk aircraft plant and the Aviastar plant.

3 March 2022

- Blocking sanctions are introduced against 22 Russian defense organizations.

- Export control is introduced for oil refining, including oil and gas production equipment.

- The Entity List (a list of entities prohibited by the US Department of Commerce, whose goods are prohibited from import/export/re-export for US citizens and legal entities) includes organizations that participated in or supported the Russian and Belarusian security services, the military and defense sectors, as well as the military and defense science projects.

- Russian aircraft are prohibited from using US airspace.

28 February 2022

- Blocking sanctions against the Russian Direct Investment Fund (RDIF) and its head Kirill Dmitriev, as well as JSC Direct Investment Management Company. Hybrid sanctions are imposed on the Central Bank of the Russian Federation, the Ministry of Finance, the National Wealth Fund are introduced.

- Otkritie Bank, Sovcombank, Novikombank, Promsvyazbank, VEB, Apple Pay and Google Pay services stopped working.

25 February 2022

- VTB: OFAC imposed major sanctions on VTB Bank, as a result of which the assets will be frozen. (General License No. 12 of the US Department of the Treasury, which gives US banks the right to reject a transaction until March 26, 2022, and block it completely after March 26).

- Sberbank: Within 30 days, OFAC closes correspondent or payment accounts of Sberbank and rejects any transactions involving Sberbank or its subsidiaries. Payments processed by Sberbank in US dollars will be interrupted and rejected.

- Due to the sanctions against Otkritie Bank, Sovcombank, Novikombank, Promsvyazbank, VEB, their work will be limited and their access to world markets, capital and investment inflows, and the use of the US dollar will be reduced. Moreover, all subsidiaries in which a 50 percent or more share belongs to Otkritie Bank or Sovcombank, respectively, are subject to sanctions.

- Gazprom, Gazpromneft, Transneft, Rostelecom, Russian Railways, Alfa-Bank, Rosselkhozbank, Ozonbank, Moscow Credit Bank, RusHydro, Alrosa, Transneft were also subject to sanctions. These companies are subject to restrictions on transactions, provision of financing and other transactions with new debt obligations with a maturity of more than 14 days.

Nadmitov, Ivanov & Partners Law Firm advises on the monitoring of UK sanctions.

Email: info@nplaw.ru
Tel.: +7 (495) 649-87-12

+7 (495) 649-87-12