On April 6, 2018, the U.S. Department of the Treasury’s (“Treasury”) Office of Foreign Assets Control (“OFAC”), in consultation with the U.S. Department of State, designated three dozen Russian “oligarchs,” government officials, and related entities as specially designated nationals (“SDNs”). All were designated under pre-existing Ukraine/Russia-related authorities provided by Executive Order (“E.O.”) 13661, relating to (among others) senior officials of the Government of the Russian Federation and their supporters, and E.O. 13662, relating to persons and entities operating in specified sectors of the Russian economy. Effective today, the newly designated persons and entities are included on OFAC’s list of SDNs (the “SDN List”). Treasury also designated the Russian state-owned arms export monopoly and a related financial institution as SDNs because of their activities relating to the Syrian conflict.
OFAC simultaneously released two general licenses, General Licenses 12 (“GL 12”) and 13 (“GL 13”), that authorize a two-month wind-down period for operations involving many of the specified entities and a one-month period to dispose of holdings in three of the new SDNs that are publicly listed companies. OFAC also released new Frequently Asked Questions related to both the designations and the general licenses.
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