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Parting Shots by Biden Administration in the Form of Sweeping New Russia Sanctions

By Dj Wolff, Carlton Greene, Erik Woodhouse, Jeremy Iloulian & Edward Goetz on January 21, 2025
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The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the U.S. Department of State issued new Russia sanctions on January 10th and 15th, 2025.

  • On the 10th, OFAC and the State Department aggressively targeted the Russian energy sector by designating major Russian oil companies liquefied natural gas (LNG) facilities, and senior officials of State Atomic Energy Corporation, Rosatom, as well as insurers, traders, and dozens of vessels involved in shipping Russian oil.
  • On the 15th, OFAC designated Keremet Bank, a Kyrgyz Republic-based financial institution, along with other entities involved in a sanctions evasion scheme to facilitate cross border payments for sensitive goods. Keremet Bank’s designation is the first use of authorities established by Executive Order (E.O.) 14114 (amending E.O. 14024) targeting non-US financial institutions for facilitating transactions involving Russia’s military-industrial base. OFAC also re-designated almost 100 already sanctioned entities pursuant to E.O. 13662. The State Department designated more than 150 individuals and entities involved in providing items critical to Russia’s military industrial base, including a number of PRC-based entities.

January 10 Action

In the January 10 action, OFAC and the State Department targeted entities involved in currently active Russian energy production and exports. Previously, the U.S. government limited sanctions on Russia’s energy sector to measures that sought to reduce revenues while maintaining Russia’s exports of oil, petroleum products, and gas, including (a) prohibiting imports to the United States, (b) imposing a price cap on seaborn shipments of Russian crude oil and petroleum products, and (c) targeting Russia’s development of future energy production and export capacity. 

The January 10 action changes that approach: OFAC designated Gazprom Neft (Gazprom’s oil-producing operation) and Surgutneftegaz, two of Russia’s top four oil producers, as well as dozens of their subsidiaries. The State Department designated operators of the Vostok oil project, the Portovaya LNG terminal, and the Vysotsk LNG terminal. 

The U.S. also heavily targeted Russia’s transport of oil by (a) designating 183 vessels, primarily oil tankers linked to transporting Russian oil, (b) redesignating Sovcomflot itself and revoking General License 93, which previously had suspended application of the 50% rule to Sovcomflot, (c) designating two of Russia’s largest insurers, Ingosstrakh Insurance Company and Alfastrakhovanie Group, and (d) designating multiple oil traders with ties to Russia (including non-Russian parties). 

Among other things, OFAC also:

  • Issued a determination pursuant to E.O. 14024 that authorizes the imposition of sanctions on any person determined to operate or have operated in the energy sector of the Russian Federation economy, which expands OFAC’s targeting authority for future designations. In FAQ 1213, OFAC defines “energy sector” very broadly. 
  • Issued a determination prohibiting, as of February 27, 2025, U.S. persons from providing “petroleum services” to “any person in the Russian Federation.”  OFAC defines petroleum services defined in FAQ 1216.

January 15 Action

In the January 15 action, OFAC re-designated almost 100 previously sanctioned entities pursuant to E.O. 13662. Under E.O. 13662, foreign persons, including foreign financial institutions, that knowingly facilitate significant transactions for or on behalf of any of these entities could be subject to mandatory secondary sanctions.   

OFAC also designated Keremet Bank, a Kyrgyz Republic-based financial institution, along with other entities involved in a sanctions evasion scheme to facilitate cross border payments for sensitive goods. Keremet Bank’s designation is the first use of authorities established by Executive Order (E.O.) 14114 (amending E.O. 14024) targeting non-US financial institutions for facilitating transactions involving Russia’s military-industrial base.

Can President Trump Unwind These Sanctions?

Many of the sanctions OFAC issued on January 10th and 15th were made pursuant to Executive Order 14024 (the Russian Harmful Foreign Activities Sanctions Regulations) and Executive Order 13662 (the Ukraine-/Russia-Related Sanctions Regulations).

Sanctions imposed pursuant to Executive Order 13662 are explicitly subject to a 2017 statute (the Countering America’s Adversaries Through Sanctions Act, or CAATSA) that requires the President to notify Congress of any planned significant lifting or modification of those sanctions, stipulates a mandatory Congressional review period, and allows Congress to prohibit the President from taking such steps by passing a joint resolution of disapproval.

As a result, although President Trump will have broad flexibility to modify most of the post-2022 Russia sanctions, the designations under Executive Order 13662 will be more complicated to modify or lift. 

To keep general authorizations consistent across E.O. 14024 and E.O. 13662 designations, OFAC issued General License 26 (pursuant to the Ukraine-/Russia-Related Sanctions Regulations), which it updated on January 15 to General License 26A.  General License 26A authorizes under E.O. 13662 transactions that are authorized under E.O. 14024 and its implementing regulations.

Photo of Dj Wolff Dj Wolff
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Photo of Carlton Greene Carlton Greene

Carlton Greene is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade and White Collar & Regulatory Enforcement groups. He provides strategic advice to clients on U.S. economic sanctions, Bank Secrecy Act and anti-money laundering…

Carlton Greene is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade and White Collar & Regulatory Enforcement groups. He provides strategic advice to clients on U.S. economic sanctions, Bank Secrecy Act and anti-money laundering (AML) laws and regulations, export controls, and anti-corruption/anti-bribery laws and regulations. Carlton is the former chief counsel at FinCEN (the Financial Crimes Enforcement Network), the U.S. AML regulator responsible for administering the Bank Secrecy Act.

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Photo of Erik Woodhouse Erik Woodhouse

Erik Woodhouse is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade and Financial Services groups, where he provides in-depth experience and practical solutions on sensitive economic sanctions and anti-money laundering matters, informed by his

…

Erik Woodhouse is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade and Financial Services groups, where he provides in-depth experience and practical solutions on sensitive economic sanctions and anti-money laundering matters, informed by his experience in private practice and in government at the Department of the Treasury and the Department of State.

Erik works with U.S. and foreign clients operating across borders on all aspects of these regimes, including developing and assessing compliance programs, advising on complex statutory and regulatory requirements, and leading companies through internal and government investigations. He has worked with major manufacturing and tech companies with global operations, multinational banks, investment funds and other financial services firms, and digital assets and virtual currency companies, collaborating with Crowell’s cross-disciplinary team that comprises former senior regulators, federal prosecutors, and in-house counsel.

Prior to joining Crowell, Erik served as Deputy Assistant Secretary of State for Counter Threat Finance and Sanctions at the Department of State, where he played a key role in the Department’s policy development and implementation related to all U.S. country-based sanctions programs and a range of global programs. Erik worked with counterparts across the executive branch to establish and implement new sanctions programs, coordinated U.S. sanctions policy with foreign governments, and engaged with private sector stakeholders on a range of U.S. sanctions priorities. Erik’s prior government experience also includes service at the Department of the Treasury’s Office of International Affairs.

Earlier in his career, Erik worked as a project finance attorney and litigator, as a law clerk for the Honorable M. Margaret McKeown of the U.S. Court of Appeals for the Ninth Circuit, and as a research fellow at Stanford University’s Program on Energy & Sustainable Development.

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Photo of Jeremy Iloulian Jeremy Iloulian

Recognized as a “Rising Star” in International Trade by Super Lawyers, Jeremy Iloulian advises clients globally on complex cross-border regulatory, compliance, investigative, and transactional matters and policy developments that touch U.S. national security, international trade, and foreign investment, including those relating to

…

Recognized as a “Rising Star” in International Trade by Super Lawyers, Jeremy Iloulian advises clients globally on complex cross-border regulatory, compliance, investigative, and transactional matters and policy developments that touch U.S. national security, international trade, and foreign investment, including those relating to U.S. export controls (EAR and ITAR), economic sanctions, anti-boycott laws, the Committee on Foreign Investment in the United States (CFIUS), and various national security controls on fundamental research and supply chains.

Jeremy has extensive experience counseling U.S. and non-U.S. clients, including public and private companies, private equity sponsors, and nonprofits spanning a multitude of industries, including aerospace and defense, energy, entertainment, fashion, food and beverage, health care, infrastructure, technology, telecommunications, and transportation. He provides strategic guidance on managing risks for dealings in high-risk jurisdictions such as China, Russia, Venezuela, and the Middle East, among other countries and regions. He regularly advocates on behalf of such clients before the U.S. Bureau of Industry and Security (BIS), Directorate of Defense Trade Controls (DDTC), Office of Foreign Assets Control (OFAC), Bureau of Economic Affairs (BEA), Census Bureau, Department of Energy, and Nuclear Regulatory Commission (NRC).

Additionally, Jeremy has previously counseled on, presented on, and published research related to international environmental law, specifically the United Nations Convention on the Law of the Sea (UNCLOS) and Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES).

Prior to and during law school, Jeremy interned at multiple government agencies, including the United Nations, the U.S. State Department, and the Iraqi Embassy in Washington, D.C.

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Photo of Edward Goetz Edward Goetz

Edward Goetz is the Director for International Trade Services in Crowell & Moring’s Washington, D.C. office. Edward leads the firm’s international trade analysts providing practice support to the International Trade Group in the areas of customs regulations, trade remedies, trade policy, export control…

Edward Goetz is the Director for International Trade Services in Crowell & Moring’s Washington, D.C. office. Edward leads the firm’s international trade analysts providing practice support to the International Trade Group in the areas of customs regulations, trade remedies, trade policy, export control, economic sanctions, anti-money laundering (AML), anti-corruption/anti-bribery, and antiboycott. He has extensive government experience providing information and interpretive guidance on the International Traffic in Arms Regulations (ITAR) concerning the export of defense articles, defense services, and related technical data. He also assists attorneys with matters involving the Export Administration Regulations (EAR), economic sanctions, AML, anti-corruption/anti-bribery, and trade remedies.

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  • Posted in:
    Banking, Finance and Securities, Government and Public Policy
  • Blog:
    International Trade Law
  • Organization:
    Crowell & Moring LLP
  • Article: View Original Source

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