OFAC Targets Defense Sector and Gold Imports in Additional Russian Sanctions

OFAC sanctioned additional individuals and entities in an effort to "strike at the heart of Russia's ability to develop and deploy weapons and technology used for Vladimir Putin's brutal war of aggression against Ukraine." In a series of actions, OFAC published five new general licenses and a new executive order determination, as well as two FAQs - one new and one amended.

The actions, pursuant to EO 14024 ("Blocking Property With Respect To Specified Harmful Foreign Activities of the Government of the Russian Federation") and EO 14065 ("Blocking Property of Certain Persons and Prohibiting Certain Transactions With Respect to Continued Russian Efforts To Undermine the Sovereignty and Territorial Integrity of Ukraine"), resulted in 70 entities being designated for sanctions by OFAC. In a coordinated action, the U.S. Department of State sanctioned an additional 45 entities and 29 individuals.

The five new general licenses include: (i) General License No. 39 ("Authorizing the Wind Down of Transactions Involving State Corporation Rostec"); (ii) General License No. 40 ("Civil Aviation Safety"); (iii) General License No. 41 ("Authorizing Certain Transactions Related to Agricultural Equipment"); (iv) General License No. 42 ("Authorizing Certain Transactions with the Federal Security Service"); and (v) General License No. 43 ("Divestment or Transfer of Debt or Equity of, and Wind Down of Derivative Contracts Involving, Public Joint Stock Company Severstal or Nord Gold PLC").

OFAC also published a new determination under Section 1(a)(i) of EO 14068 ("Prohibiting Certain Imports, Exports, and New Investment With Respect to Continued Russian Federation Aggression"), which expanded the import prohibitions under the executive order to gold exported from the Russian Federation. Pursuant to the determination, importing gold that originated from the Russian Federation is now prohibited except for gold that was located outside of Russia prior to June 28, 2022.

To further clarify the new prohibitions, OFAC issued FAQ 1070 and amended FAQ 1029.

The Department of State said that it plans to impose visa restrictions on officials believed to have threatened or violated Ukraine's sovereignty, restrictions that would affect more than 500 Russian Federation officials.