Sanctions Alert: U.S. Imposes a Range of Additional Sanctions, Export Controls and Other Measures Against Russia

May 12, 2021

In the wake of the meeting between President Joseph Biden, other G7 Leaders and President Zelenskyy of Ukraine, the United States on Sunday May 8 announced a range of measures to expand the U.S. Department of the Treasury’s sanctions, export controls and other policies designed to pressure Russia in response to its actions against Ukraine.

The sanctions imposed against Russian interests in response to the war in Ukraine on Sunday include new sanctions against:

  • Russia’s directly or indirectly controlled television stations (Joint Stock Company Channel One Russia, Television Station Russia-1, and Joint Stock Company NTV Broadcasting Company);
  • Limited Liability Company Promtekhnologiya, which produces rifles and other weapons that have been used in military operations in Ukraine;
  • seven shipping companies, which own or operate 69 vessels1; and one marine towing company (OOO Fertoing);
  • eight executives from Sberbank;
  • twenty-seven executives from Gazprombank; and
  • Moscow Industrial Bank and its ten subsidiaries.

The United States has also extended the prohibition set out in Executive Order 14024 on doing business with various key sectors of the Russian economy, by prohibiting U.S. persons from providing accounting, trust and corporate formation, and management consulting services to any person in the Russian Federation. These prohibitions take effect at 12:01 a.m. EDT June 7, 2022, subject to General License No. 34, under which (generally speaking) U.S. persons may conduct transactions ordinarily incident and necessary to the wind down of such services, through 12:01 a.m. EDT, July 7, 2022. After those times, persons who continue to operate in such sectors would be subject to sanctions as provided in E.O. 14024 and its implementing regulation.

With respect to export controls, the United States also announced it will issue a new rule that imposes additional restrictions on Russia’s industrial sector; and stated that the Nuclear Regulatory Commission will also suspend general licenses for exports of source material, special nuclear material, byproduct material, and deuterium to Russia.

The United States also imposed approximately 2,600 visa restrictions on Russian and Belarussian officials and introduced a new visa restriction policy applicable to Russian Federation military officials and Russia-backed or Russia-installed purported authorities who are believed to have been involved in human rights abuses, violations of international humanitarian law, or public corruption in Ukraine.

We will continue to closely monitor developments in this space.

If you have any questions regarding the matters covered in this e-mail, please contact Bruce Paulsen (212) 574-1533, Brian Maloney (212) 574-1448 or your primary Seward & Kissel attorney.

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1 The shipping companies and associated vessels added to OFAC’s list of specially designated nationals in its May 8, 2022 announcement are: (i) M Leasing LLC (and the vessels Adler, Angara, and Ascalon); (ii) Oboronlogistika OOO (and the vessels Ambal, Maria E (a.k.a. Maria), and Sparta II); (iii) Transmorflot LLC (and the vessels Anastasiia, Askar-Sarydzha, Etim Emin, Gasret Aliev, Genrikh Gasanov, Kompozitor Gasanov, Lady D (f/k/a Maliy B.S.), Lady Mariia (f/k/a Stella-Maria), Lady R, Maia-1 (f/k/a Neptun), Olga, Port Olya-1, Port Olya-2, Rasul Gamzatov, Sona, and Valentin Emirov); (iv) Joint Stock Company Northern Shipping Company (and the vessels Belomorskiy, Chizhovka, Dvinskiy Zaliv, Inzhener Trubin, Inzhener Veshnyakov, Iohann Mahmastal, Kapitan Kokovin, Kapitan Ryntsyn, Kapitan Sakharov, Kholmogory, Lapominka, Mekhanik Brilin, Mekhanik Kottsov, Mekhanik Kraskovskiy, Mekhanik Makarin, Mekhanik Pustoshnyy, Mekhanik Pyatlin, Mekhanik Yartsev, Mikhail Lomonosov, S. Kuznetsov, Siyanie Severa, SMP Arkhangelsk, SMP Novodvinsk, SMP Severodvinsk, Teriberka, Triton, and Viktor Zabelin); (v) Nord Project LLC Transport Company (and the vessels Enisey, NP Dikson, NP Dudinka, RZK Constanta, Sabetta, Severniy Project, Siberia, Taibola, Taimyr, Tambey, Teriberka, Terskiy Bereg, Tiksy, Turukhan, and Utrenniy); (vi) SC South LLC (and the vessels Pizhma, Sparta, Sparta III and Sparta IV); and (vii) Marine Trans Shipping LLC (and the vessel Polar Rock).