Sanctions Update: U.S. Announces Broader Oligarch Sanctions and Additional Measures

March 7, 2022

On March 3, 2022, the U.S. announced additional sanctions against numerous Russian oligarchs and their families, as well as the targeting of their property interests, including luxury yachts and aircraft. The U.S. also sanctioned numerous Russian defense-related entities supporting the invasion of Ukraine. Identifying information for the individuals, entities, aircraft, and vessels sanctioned can be found here. The U.S. Department of State’s announcement can be found here, as well as a fact sheet.

In coordination with the new oligarch sanctions, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued new General License 15, which authorizes all transactions otherwise prohibited by the Russian Harmful Foreign Activities Sanctions Regulations involving any entity owned 50 percent or more (directly or indirectly) by Alisher Burhanovich Usmanov that is not specifically listed on OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List).

The U.S. Department of Justice (DOJ) also unsealed a criminal indictment on March 3, 2022 charging a U.S. citizen with violations of U.S. sanctions and false statements in connection with services provided to Russian oligarch Konstantin Malofeyev, who had previously been designated as a Specially Designated National (SDN) pursuant to E.O. 13660 as a main source of financing for Russia’s promotion of separatism in the Crimea Region of Ukraine, and providing financial, material, or technological support for, or goods and services to or in support of, the Donetsk People’s Republic. The DOJ also announced on March 2, 2022 the launch of its Task Force KleptoCapture, which is an interagency law enforcement task force dedicated to enforcing the new Russia sanctions.

Finally, the New York State Department of Financial Services (DFS) announced on March 2, 2022 that it would strengthen its enforcement of U.S. sanctions laws, including by procuring additional blockchain analytics technology, which will reportedly allow DFS to detect exposure among DFS-licensed virtual currency businesses to sanctioned Russian individuals, financial institutions, and other entities.

In short, U.S. sanctions against Russia are developing at a rapid pace. We will continue to track these developments closely. If you have any questions regarding U.S. sanctions, please contact Bruce Paulsen (212-574-1533), Michael Considine (212-574-1334), or Andrew Jacobson (212-574-1477) of Seward & Kissel’s Sanctions Practice Group.