U.S. Sanctions Russian Oligarchs, Government Officials, and Major Companies

By: Michael T. Gershberg, Justin A. Schenck

On April 6, 2018, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) sanctioned seven Russian oligarchs, 12 companies controlled by those oligarchs, 17 senior Russian government officials, a state-owned Russian weapons trading company, and a Russian bank.  These SDN designations were made pursuant to the Countering America's Adversaries Through Sanctions Act (CAATSA) and Executive Orders related to the Ukraine and Syria sanctions programs.  U.S. Treasury Secretary Steven Mnuchin stated that these sanctions were in response to the Russian government's activities in Ukraine and Syria as well as other anti-Western actions worldwide.  The Russian oligarchs were targeted in particular because “the Russian government operates for the disproportionate benefit of oligarchs and government elites.”  OFAC also issued two general licenses to minimize disruption to U.S. persons and businesses from these designations, including authorization for activities to wind-down operations or agreements with newly sanctioned entities.  This round of sanctions covers companies heavily involved in global trade, and its impact will be significant in the U.S. and worldwide.  U.S. persons who do business with Russia or Russian companies should carefully review these business relationships, ensure they are in compliance with sanctions laws, and prepare for the possibility of additional Russian sanctions in the future.

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