On March 20, 2014, President Obama issued a third Executive Order expanding the scope of sanctions against Russian and Ukrainian persons related to Russia’s recent vote to annex Crimea and its continuing efforts to undermine Ukraine’s security, stability and sovereignty. This Executive Order authorizes possible further sanctions on “key sectors” of the Russian economy, such as financial services, energy, metals and mining, engineering, and defense and related materiel. This is a significant development in the administration’s efforts to impose further potential economic sanctions against Russia if President Vladimir Putin does not act to de-escalate the continuing crisis in Ukraine.

In addition, pursuant to the earlier Executive Orders, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has designated 20 additional Russian government officials and a Russian bank for sanctions. This expanded list includes major Putin allies, e.g., his chief of staff, Sergei Ivanov; the speaker of the State Duma, Sergey Naryshkin; and financier Yuri Kovalchuk, often called Putin’s personal banker. The bank listed is Bank Rossiya, which reportedly holds the accounts of numerous top Russian government officials and has correspondent accounts in the United States and Europe.

As a result of Treasury’s action, assets of the persons designated that are within U.S. jurisdiction must be frozen. Additionally, transactions by U.S. persons or within the United States involving the individuals and banking entity designated are generally prohibited. See the Treasury website for the list of persons added to the Specially Designated Nationals (SDN) List.