On December 22, the Treasury Department’s Office of Foreign Assets Control (OFAC) designated more than 30 individuals and entities under the Ukraine-related sanctions. The designations were made under the auspices of several different executive orders, and thus there are different restrictions on transacting with these parties depending on the basis for each party’s designation. Roughly 72 hours before Christmas Day, when the spirit of giving is celebrated, OFAC showed its ability to taketh away, as follows:

  • Eight individuals and entities were designated because they are owned or controlled by, provide material support to, or act on behalf of Gennady Timchenko, a Russian businessman who is already a Specially Designated National (SDN)
  • Three entities were designated because they are owned or controlled by Arkady and Boris Rotenberg, Russian businessmen who are already designated as SDNs
  • Three individuals were designated because they act on behalf of Kalashnikov Concern and/or Izhevsky Mekhanichesky Zavod JSC, each of which is already designated as an SDN
  • Two individuals were designated for threatening the security and stability of Ukraine and misappropriating public assets. Each is a former official from the regime of former Ukrainian President Viktor Yanukovych, who is also designated as an SDN
  • Six Ukrainian separatists were designated for violating Ukraine’s sovereignty and territorial integrity
  • Twelve entities, ranging from banks to wineries (no fun allowed in Crimea!), that operate in the Crimea region of Ukraine were designated

In addition to these designations, a number of subsidiaries of previously sanctioned entities (VTB Bank, Sberbank and Rostec) were added to the Sectoral Sanctions Identification List, and thus made subject to targeted restrictions.

These measures suggest that the United States remains serious about pressuring Russia to reach an acceptable diplomatic resolution in Ukraine. In addition, and notably, these measures help to align US restrictions related to Ukraine with restrictions maintained by the European Union. In our view, US sanctions have the most impact when implemented in coordination with those adopted by its allies. We suspect these newly designated parties would presumably agree that being on multiple naughty lists is worse than just being on one.