On December 22, 2015, the U.S. Office of Foreign Assets Control (“OFAC”) announced that it had added 34 parties (i.e., 12 individuals and 22 entities) to the Specially Designated Nationals and Blocked Persons List (“SDN List”) and 86 entities to the Sectoral Sanctions Identifications List (“SSI List”) under the U.S. Government’s Russia/Ukraine-related Sanctions Program. In a press release, OFAC stated that these designations are part of its continued efforts to counter attempts to circumvent U.S. Russia/Ukraine-related sanctions, to further align U.S. sanctions with those of its international allies, and to provide additional information to assist the private sector with sanctions compliance. OFAC’s announcement followed the European Union’s decision earlier this week to extend sanctions against Russia for six months in response to the prolonged failure to fully implement the Minsk Agreements.
The 34 parties added to the SDN List were designated under Executive Orders 13661, 13660, or 13685. Of note, the new SDNs include three Russian banks (i.e., Joint Stock Company Genbank, Open Joint Stock Company Krasnodar Regional Investment Bank, and Open Joint Stock Company Commercial Bank Verkhnevolzhsky); one Crimea-based bank (i.e., Sevastopolsky Morskoy Bank); and a Crimean state-owned enterprise engaged in air transportation (i.e., State Enterprise Universal-Avia). U.S. Persons are generally prohibited from dealing, directly or indirectly, with parties listed on the SDN List as well as with any entities 50% or more owned by one or more SDNs.
The 86 entities added to the SSI List are subsidiaries of VTB Bank, Sberbank, or Rostec, which were previously subject to sectoral sanctions pursuant to Executive Order 13662. The 86 subsidiaries added to the SSI List were already subject to the same financing restrictions as their respective parent entities, because they were 50% or more owned by one or more parties listed on the SSI List (“SSIL Entities”). OFAC stated that adding these parties to the SSI List will help the public “more effectively comply with the sanctions on VTB Bank, Sberbank, and Rostec.” U.S. Persons are restricted from certain types of dealings with SSIL Entities, although these restrictions are not a complete prohibition unlike for SDNs.