Over 300 new sanctions issued across Treasury and State
Foreign financial institutions that support Russia’s war economy face greater risk of sanctions
WASHINGTON – As President Biden and Group of Seven (G7) Leaders prepare to meet this week in Italy, the U.S. Department of the Treasury is issuing sweeping new measures guided by G7 commitments to intensify the pressure on Russia for its continued cruel and unprovoked war against Ukraine. Today’s actions ratchet up the risk of secondary sanctions for foreign financial institutions that deal with Russia’s war economy; restrict the ability of Russian military-industrial base to take advantage of certain U.S. software and information technology (IT) services; and, together with the Department of State, target more than 300 individuals and entities both in Russia and outside its borders-including in Asia, the Middle East, Europe, Africa, Central Asia, and the Caribbean-whose products and services enable Russia to sustain its war effort and evade sanctions.
“Russia’s war economy is deeply isolated from the international financial system, leaving the Kremlin’s military desperate for access to the outside world,” said Secretary of the Treasury Janet L. Yellen. “Today’s actions strike at their remaining avenues for international materials and equipment, including their reliance on critical supplies from third countries. We are increasing the risk for financial institutions dealing with Russia’s war economy and eliminating paths for evasion, and diminishing Russia’s ability to benefit from access to foreign technology, equipment, software, and IT services. Every day, Russia continues to mortgage its future to sustain its unjust war of choice against Ukraine.”
Treasury is targeting the architecture of Russia’s financial system, which has been reoriented to facilitate investment into its defense industry and acquisition of goods needed to further its aggression against Ukraine. Treasury is also targeting more than a dozen transnational networks laundering gold for a designated Russian gold producer, supporting Russia’s production of unmanned aerial vehicles (UAVs), and procuring sensitive and critical items such as materials for Russia’s chemical and biological weapons program, anti-UAV equipment, machine tools, industrial machinery, and microelectronics. Today’s action also takes further steps to limit Russia’s future revenue from liquefied natural gas.
The State Department is targeting over 100 entities and individuals engaged in the development of Russia’s future energy, metals, and mining production and export capacity; sanctions evasion and circumvention; and furthering Russia’s ability to wage its war against Ukraine.
NEW SECONDARY SANCTIONS RISK
On December 22, 2023, President Biden expanded Treasury’s tools to disrupt and degrade Russia’s war machine by authorizing Treasury to impose sanctions on foreign financial institutions for aiding Russia’s military-industrial base. Today, Treasury is broadening the definition of Russia’s military-industrial base to include all persons blocked pursuant to Executive Order (E.O.) 14024. This means that foreign financial institutions risk being sanctioned for conducting or facilitating significant transactions, or providing any service, involving any person blocked pursuant to E.O. 14024, including designated Russian banks such as VTB Bank Public Joint Stock Company (VTB) and Public Joint Stock Company Sberbank of Russia (Sberbank). This expanded definition reflects Treasury’s assessment that Russia has re-oriented its economy and marshalled all parts of its government toward supporting its reprehensible war effort. Foreign financial institutions face sanctions risk for continuing to facilitate transactions involving Russia’s military-industrial base. Financial institutions should review OFAC’s updated sanctions advisory for practical guidance on how to identify sanctions risks and implement corresponding controls.
FOREIGN LOCATIONS OF DESIGNATED RUSSIAN BANKS
To help clarify the risk foreign financial institutions face by conducting or facilitating significant transactions or providing any service involving Russia’s designated banks, OFAC has updated the Specially Designated Nationals and Blocked Persons List (SDN List) information for five sanctioned Russian financial institutions, to include the addresses and aliases of their foreign locations.
Specifically, OFAC has updated the listings for Promsvyazbank Public Joint Stock Company to include its locations in Beijing, People’s Republic of China (PRC), Bishkek, Kyrgyz Republic, and New Delhi, India; for State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank to include its locations in Beijing, PRC and Mumbai, India; for Sberbank to include its locations in Beijing, PRC and New Delhi and Mumbai, India; for VTB to include its locations in New Delhi, India, and Beijing and Shanghai, PRC; and for VTB Capital Holdings Closed Joint Stock Company to include its location in Hong Kong, PRC.
SOFTWARE AND IT-RELATED SERVICES PROHIBITIONS
In coordination with the U.S. Department of Commerce and in line with G7 efforts to disrupt the Russian military-industrial base’s reliance on foreign IT systems, Treasury has taken steps to restrict the Russian military-industrial base’s access to certain software and IT-related services. To implement this policy, Treasury, in consultation with the Department of State, has issued a new determination under Executive Order (E.O.) 14071, which prohibits the supply to any person in the Russian Federation of (1) IT consultancy and design services; and (2) IT support services and cloud-based services for enterprise management software and design and manufacturing software. The determination will take effect on September 12, 2024.
The United States strongly supports the free flow of information and communications globally, and these actions are not intended to disrupt civil society and civil telecommunications. Despite the new prohibitions, OFAC continues to maintain authorizations for certain telecommunication and internet-related transactions, as well as humanitarian transactions, under General Licenses 6D and 25D, which mitigate the impacts to Russian civil society and protect public access to information communications technology.
RUSSIAN FINANCIAL INFRASTRUCTURE
The Moscow Exchange (MOEX) operates Russia’s largest public trading markets for equity, fixed income, derivative, foreign exchange, and money market products, as well as Russia’s central securities depository and the country’s largest clearing service provider. U.S.-designated Russian President Vladimir Putin has approved a series of measures to further attract capital through MOEX from both Russian and non-Russian persons from “friendly countries”-expanding opportunities for both Russians and non-Russians to profit from the Kremlin’s war machine by making investments in Russian sovereign debt, Russian corporations, and leading Russian defense entities, including U.S.-designated State Corporation Rostec, Public Joint Stock Company United Aircraft Corporation (UAC), Kamaz Publicly Traded Company (Kamaz), Irkut Corporation Joint Stock Company, Uralvagonzavod, and Joint Stock Company Russian Helicopters.
The National Clearing Center (NCC) is the central counterparty and clearing agent for, and a subsidiary of, MOEX. NCC is supervised by the Central Bank of the Russian Federation (CBR).
The Non-Bank Credit Institution Joint Stock Company National Settlement Depository (NSD) is Russia’s central securities depository and is a subsidiary of MOEX. NSD provides bank account services, registration of over-the-counter trades, and liquidity management services. The European Union (EU) previously sanctioned NSD in June 2022.
Gas Industry Insurance Company Sogaz (Sogaz) is an insurance company that provides insurance to Russian military personnel and personnel of leading defense entities, including U.S.-designated UAC, Joint Stock Company Experimental Design Bureau Novator, and Federal State Enterprise Ya M Sverdlov Plant. Sogaz has also been sanctioned by Australia, Canada, the EU, New Zealand, and the United Kingdom (UK).
Joint Stock Company Russian National Reinsurance Company (RNRC) is a Russian state-owned reinsurance provider that was created in 2016 to provide protection for sanctioned persons. RNRC has also been sanctioned by the EU and UK.
MOEX, NCC, NSD, Sogaz, and RNRC were designated pursuant to E.O. 14024 for operating or having operated in the financial services sector of the Russian Federation economy. Sogaz was also designated pursuant to E.O. 14024 for operating or having operated in the defense and related materiel sector of the Russian Federation economy.
SANCTIONS EVASION, CIRCUMVENTION, AND BACKFILL
Russia relies on complex transnational supply chains to feed its war machine and enable production of materiel to sustain its war effort. Similar networks also attempt to evade sanctions using convoluted schemes to move money and other valuable goods and assets. Today’s action targets more than a dozen of these types of networks, designating more than 90 individuals and entities across Russia, Belarus, the British Virgin Islands, Bulgaria, Kazakhstan, the Kyrgyz Republic, the PRC, Serbia, South Africa, Türkiye, and the United Arab Emirates (UAE).