On September 30, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated hundreds of Russian individuals and entities and placed them on the Specially Designated Nationals (SDN) List in response to Russia’s illegal annexation of additional Ukrainian territories.
The new designations target fourteen suppliers connected to the country’s military-industrial complex, including two international suppliers, as well as three key leaders of Russia’s financial system and 278 members of Russia’s legislature. These entities are, broadly, defense procurement and supplier for Russia’s defense industrial base and Russian technology firms, and the financial leaders are, or were, related to the Central Bank of Russia. The sanctions now also extend to immediate family members of some of Russia’s senior officials, including the wife and two adult children of Russian Prime Minister Mikhail Mishustin. Additional identifying information and details on the entities sanctioned is available here.
“We will not stand by as Putin fraudulently attempts to annex parts of Ukraine,” Treasury Secretary Janet Yellen said in a press release announcing the new designations. She added that the United States will continue “our aggressive and coordinated effort to hold Putin and his enablers accountable for his unprovoked invasion, and limit their ability to prop up their economy.”
In addition to updating the SDN List, OFAC also issued Frequently Asked Question (FAQ) 1091 to provide new guidance about the heightened sanctions risk international actors outside of Russia could face if they provide material assistance, sponsorship, financial, material, or technological support for, or goods or services to sanctioned persons or activities involving Russia’s military and defense industrial base. This includes efforts to circumvent sanctions on Russia and Belarus.
Overall, OFAC’s actions were part of a joint effort, in conjunction with the Department of Commerce and the Department of State, to undermine Russia’s ability to wage war against Ukraine; the Department of Commerce added 57 entities to the Entity List (see Update of October 3, 2022), while the Department of State imposed visa restrictions on 910 individuals, including members of Russia’s military and proxy fighting force in Ukraine, and Belarussian military officials.