Following Russian President Vladimir Putin’s announcement that he would illegally annex four Ukrainian territories, the Treasury Department’s Office of Foreign Assets Control designated 14 individuals in Russia’s military industrial complex, as well as 278 members of the Russian legislature for supporting the annexation. OFAC also issued new guidance warning of heightened sanctions risk for any actors outside of Russia providing political or economic support to the country.
In a newly published FAQ, OFAC said that “the United States is prepared to more aggressively use its authorities under existing U.S. sanctions programs to target such persons whose activities may constitute material assistance, sponsorship, financial, material or technological support for, or goods or services to, or in support of (together “material support”), sanctioned persons or sanctionable activity.” The FAQ noted, however, that “OFAC will generally not impose sanctions on non-U.S. persons that engage in transactions that would be authorized for U.S. persons, such as certain energy-related transactions.”
