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OFAC Sanctions Russian Financial Entities, President Putin and Foreign Minister Lavrov

"While officially a sovereign wealth fund, [the Russian Direct Investment Fund] is widely considered a slush fund for President Vladimir Putin and is emblematic of Russia’s broader kleptocracy."
U.S. Department of the Treasury's Office of Foreign Assets Control
"While officially a sovereign wealth fund, [the Russian Direct Investment Fund] is widely considered a slush fund for President Vladimir Putin and is emblematic of Russia’s broader kleptocracy."
U.S. Department of the Treasury's Office of Foreign Assets Control

OFAC prohibited U.S. persons from engaging in transactions with the Central Bank of Russia, and imposed sanctions on President Vladimir Putin, Foreign Minister Sergei Lavrov and numerous Russian investment funds.

OFAC's new Directive 4 under E.O. 14024 prohibits U.S. person from engaging in any transaction involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation. OFAC described this action as intended to prevent Russia from financially sustaining its war by deploying its international reserves in a way that would undermine the impact of U.S. Sanctions. OFAC also designated the Russian Direct Investment Fund ("RDIF"), its management company, one of the managing company’s subsidiaries, and RDIF's CEO. OFAC stated that the sovereign wealth fund RDIF is "widely considered a slush fund for President Vladimir Putin and is emblematic of Russia’s broader kleptocracy."

A number of members of the Russian leadership have also been sanctioned by OFAC, including President Putin and Minister Sergei Lavrov. OFAC stated that it will impose more sanctions against those most responsible for Russia’s hostile actions against Ukraine, including Russia’s most powerful and elite, if the war persists.

FINRA issued Regulatory Notice 22-06 to keep member firms up to date on OFAC’s efforts to ensure that the United States goal of cutting Russia’s access to any U.S. financial resources are met, and not undermined by associated Russian financial institutions.

Primary Sources

  1. Treasury Press Release: Treasury Prohibits Transactions with Central Bank of Russia and Imposes Sanctions on Key Sources of Russia’s Wealth 268
  2. Executive Order 14024: Blocking Property With Respect To Specified Harmful Foreign Activities of the Government of the Russian Federation
  3. Treasury Press Release: U.S. Treasury Imposes Sanctions on Russian Federation President Vladimir Putin and Minister of Foreign Affairs Sergei Lavrov
  4. FINRA Regulatory Notice 22-06: U.S. Imposes Sanctions on Russian Entities and Individuals

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Tags

Regulated Activities
Sanctions Compliance
Sub-Activity
Sanctions Based on Country
Body of Law
Sanctions
Jurisdiction
US - Federal
Impacted Foreign Jurisdiction
Russia , Ukraine
Organization
President / White House Treasury / FinCEN / OFAC / CFIUS
Sub-Author
OFAC