On February 23, 2024, the US Treasury Department’s Office of Foreign Assets Control (OFAC), in conjunction with the US State Department, added over 500 entities and individuals to the Specially Designated Nationals and Blocked Persons List (SDN List), and the US Department of Commerce’s Bureau of Industry and Security (BIS) announced the addition of over 90 entities to the Entity List, to mark the two-year anniversary of Russia’s invasion of Ukraine and as a response to the death of pro-democracy Russian opposition leader Aleksey Navalny.
The designations focused on Russian entities and individuals directly or indirectly involved in Russia’s invasion of Ukraine and human rights abuses, as well as non-Russian individuals and entities that have assisted Russia to evade or circumvent US sanctions on Russia.
This latest action underscores the continued risk involved in transacting with entities in and out of Russia that directly or indirectly support Russia’s invasion of Ukraine; the global reach of the designations; the pitfalls companies may face in the absence of risk-based sanctions, export control, and anti-money laundering compliance measures; and the US’s continued commitment to a whole-of-government approach in this area.
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