Today, the United States imposed another round of sanctions on Russia, targeting Russian elites, universities, and technological institutions.
Blocking Sanctions
The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) added the following notable Russian elites to the List of Specially Designated Nationals (SDN), subjecting them to full U.S. blocking sanctions:
- Andrey Grigoryevich Guryev, Russian billionaire oligarch and son, Andrey Andreevich Guryev, of PhosAgro PJSC, a leading fertilizer company;
- Viktor Filippovich Rashnikov, a Russian billionaire oligarch of Russia’s iron and steel industry;
- Alina Maratovna Kabaeva, former member of the State Duma; and
- Natalya Valeryevna Popova, a prominent official of Russia’s technology sector.
Guryev, Rashnikov, and Kabaeva are also subject to EU asset freeze restrictions. OFAC, in tandem with the State Department, also designated a number of Russian businesses and institutions as SDNs, including prominent Russian educational and technological institutions:
- Skolkovo Foundation;
- Skolkovo Institute of Science and Technology;
- Technopark Skolkovo Limited Liability Company;
- Joint Stock Company Promising Industrial and Infrastructure Technologies;
- Joint Stock Company Penzensky Nauchno Issledovatelsky Elektrotekhnichesky Higher Education Institution;
- JSC Zelenograd Nanotechnology Center;
- Federal State Budgetary Scientific Institution Research and Production Complex Technology Center;
- JSC Scientific Research Institute Submicron; and
- Academician A.L. Mints Radiotechnical Institute Joint Stock Company.
Business with—and any dealings in the property or interests in property of—parties subject to U.S. blocking sanctions are broadly prohibited absent prior authorization from OFAC. U.S. persons must also report any property or interests in property of the blocked parties in their possession or control to OFAC within 10 business days.
Guidance and General Licenses
With today’s designations, OFAC also issued general licenses and published new guidance on the intended scope of the sanctions. The general licenses authorize, among other things, certain transactions related to civil aviation safety, the winding down or pre-existing transactions with certain newly listed parties, and the divestment of holdings in recently blocked entities.
Importantly, OFAC indicates in new FAQs that the agency currently does not view PhosAgro PJSC as subject to blocking sanctions via application of the 50 percent rule, and stresses that agricultural and medical trade are not the focus of the U.S. sanctions on Russia.
Please contact our sanctions and export team with any questions regarding these latest developments.