Overview of Sanctions imposed on Russia under the Biden Administration until the end of 2024.
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Table of Content:
Executive Summary of Changes Since August 28, 2024
I. Overview of OFAC Economic Sanctions Regulations Relating to Russia
A. Ukraine-/Russia-related Sanctions Regulations
B. Russian Harmful Foreign Activities Sanctions
II. OFAC Restrictions on Doing Business in Ukraine (Covered Regions)
Imposition of embargoes on Crimea and the Donetsk People’s Republic and Luhansk People’s Republic regions of Ukraine
III. Import Restrictions on Goods from Russia or of Russian Origin
A. Import Ban on Crude Oil, Petroleum and Related Energy Products
B. Import Ban on Items from Key Sectors (for example, seafood, alcohol and non-industrial diamonds)
C. Import Ban on Gold
D. Import Ban on Aluminum, Copper, and Nickel
IV. Restrictions on the Export of Key Services to Russia by U.S. persons
Export bans on accounting services, trust and corporate formation services, management consulting services, quantum computing, architecture services, and engineering services; and certain services related to aluminum, copper and nickel of Russian origin.
V. Restrictions Regarding Maritime Services in Connection with Russian Crude Oil and Petroleum Products
Summary of restrictions on the provision of certain services related to maritime transport of Russian origin crude oil and petroleum products:
A. Services Related to Crude Oil Transport
B. Services Related to Petroleum Products Transport
C. Country of Origin Guidance
D. Future Developments
E. Evasion Alert
VI. Sanctions Relating to Numerous Russian Economic Sectors
Persons determined to operate or to have operated in numerous sectors of the Russian economy may be sanctioned. The sectors are:
technology, defense and related materials as of April 15, 2021;
financial services as of February 22, 2022;
aerospace industries, electronics and marine as of March 31, 2022;
accounting services, trust and corporate formation services and management consulting services as of May 8, 2022;
quantum computing as of September 15, 2022;
metals and mining as of February 24, 2023; and
architecture, engineering, construction, manufacturing, and transportation as of May 19, 2023.
VII. Restrictions Regarding Financial Institutions, Financial Transactions and Related Transactions with Russia
A. Investment Prohibition
B. U.S.-Denominated Banknotes
C. Debt and Equity Restrictions
D. Amended Directive 4 and Reporting Requirements
E. Designations of Financial Institutions and Executives and Board Members of Financial Institutions as SDNs
F. Secondary Sanctions Against Foreign Financial Institutions
VIII. Other Specially Designated National and Blocked Person Designations
Additional SDN designations include oligarchs, Russian elites, TV stations, key industry entities, vessels, and aircraft.
IX. Humanitarian-Related Authorizations for Certain Activities In or Involving Russia Sanctions
Executive Summary of Changes Since August 28, 2024
In response to Russia’s ongoing invasion of Ukraine, the U.S. government has adopted a broad strategy across all branches to enforce sanctions and stricter export controls on Russia and Belarus. This alert outlines the key economic sanctions imposed by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC).