Yesterday, the US Treasury Department, Office of Foreign Assets Control (OFAC) designated several new Russian and Ukrainian Specially Designated Nationals (SDNs) and Sectoral Sanctions Identification (SSI) List entities under the Ukraine-Related Sanctions Regulations (31 C.F.R. Part 589). The designations are explained in a press release and set out in detail in a web notice. The new SDNs, which must be “blocked” by US persons, consist of separatist leaders, entities engaged in sanctions evasion, and Crimean entities. The new SSI entities, which consist of subsidiaries of Gazprom, Gazprombank, and Bank of Moscow, are subject to certain restrictions on US financing (in the case of the Gazprombank and Bank of Moscow subsidiaries) and exports (in the case of Gazprom subsidiaries) that we previously have summarized. Notably, the newly designated SSI entities were all previously subject to sanctions, since they are owned 50 percent or greater by sanctioned entities. OFAC now has formalized those restrictions by specifically designating the entities on the SSI List.
