Thursday, February 24, 2022

President Biden Announces 2nd Tranche of Sanctions (With Links to Text of Sanctions Regulations)

 


With the start of a more comprehensive military invasion of the entirety of Ukraine by Russian forces, Mr. Biden imposed a 2nd tranche of more comprehensive sanctions on Russia and Belarus. Mr. Biden said, in his remarks, declared: "Putin is the aggressor. Putin chose this war. And now he and his country will bear the consequences," Biden said, laying out a set of measures that will "impose severe cost on the Russian economy, both immediately and over time." (Biden imposes additional sanctions on Russia: 'Putin chose this war')

Included were the following:

Pix Credit: Video of Address

--Severing the connection to the U.S. financial system for Russia’s largest financial institution, Sberbank,

--Full blocking sanctions on Russia’s second largest financial institution, VTB Bank (VTB)

--Full blocking sanctions on three other major Russian financial institutions:

--New debt and equity restrictions on thirteen of the most critical major Russian enterprises and entities

--Additional full blocking sanctions on Russian elites and their family members: Sergei Ivanov (and his son, Sergei), Andrey Patrushev (and his son Nikolai), Igor Sechin (and his son Ivan), Andrey Puchkov, Yuriy Solviev (and two real estate companies he owns), Galina Ulyutina, and Alexander Vedyakhin.

--Costs on Belarus for supporting a further invasion of Ukraine

--Sweeping restrictions on Russia’s military to strike a blow to Putin’s military and strategic ambitions.

--Russia-wide restrictions to choke off Russia’s import of technological goods critical to a diversified economy and Putin’s ability to project power.

--Historical multilateral cooperation that serves as a force multiplier in restricting more than $50 billion in key inputs to Russia- impacting far more than that in Russia’s production. (FACT SHEET: Joined by Allies and Partners, the United States Imposes Devastating Costs on Russia )

 In the meantime, "European Union leaders have agreed to impose sanctions against Russia that will have "massive and severe consequences." During an emergency summit Thursday to condemn the invasion of Ukraine, the 27 member countries' leaders approved punitive measures against Russia's financial, energy and transport sectors and restrictions on exports and financing. They also added more Russian individuals to its earlier sanctions list. The sanctions must still be legally approved and published before they become effective." (European Union agrees to hit Russia with sanctions).

See also 

(1) Sberbank, OFAC issued Directive 2 under E.O. 14024, “Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions” (the “Russia-related CAPTA Directive”)

(2)  OFAC’s List of Foreign Financial Institutions Subject to Correspondent Account or Payable-Through Account Sanctions (CAPTA List)

(3) OFAC, Directive 3 under E.O. 14024, “Prohibitions Related to New Debt and Equity of Certain Russia-related Entities” (the “Russia-related Entities Directive”)

(4) identifying information on the individuals and entities sanctioned today; and 

(5) Treasury’s concurrent designation of critical Belarusian state-owned banks, defense firms, and regime-connected individuals .

 The (1) FACT SHEET: Joined by Allies and Partners, the United States Imposes Devastating Costs on Russia along with (2)Press Releases: U.S. Treasury Announces Unprecedented & Expansive Sanctions Against Russia, Imposing Swift and Severe Economic Costs (including Annexes identifying targeted entities and people and with links to the text of the regulations) follows below.


FACT SHEET: Joined by Allies and Partners, the United States Imposes Devastating Costs on Russia

 Russia to Face Massive Costs from its Isolation from the Global Financial and Trade System and Cutting-Edge Technology

Today, the United States, along with Allies and partners, is imposing severe and immediate economic costs on Russia in response to Putin’s war of choice against Ukraine. Today’s actions include sweeping financial sanctions and stringent export controls that will have profound impact on Russia’s economy, financial system, and access to cutting-edge technology. The sanctions measures impose severe costs on Russia’s largest financial institutions and will further isolate Russia from the global financial system. With today’s financial sanctions, we have now targeted all ten of Russia’s largest financial institutions, including the imposition of full blocking and correspondent and payable-through account sanctions, and debt and equity restrictions, on institutions holding nearly 80% of Russian banking sector assets. The unprecedented export control measures will cut off more than half of Russia’s high-tech imports, restricting Russia’s access to vital technological inputs, atrophying its industrial base, and undercutting Russia’s strategic ambitions to exert influence on the world stage. The impact of these measures will be significantly magnified due to historical multilateral cooperation with a wide range of Allies and partners who are mirroring our actions, inhibiting Putin’s ambition to diversify Russia’s brittle, one-dimensional economy. The scale of Putin’s aggression and the threat it poses to the international order require a resolute response, and we will continue imposing severe costs if he does not change course.

Putin’s threatening actions and now his unprovoked aggression toward Ukraine are being met with an unprecedented level of multilateral cooperation. The United States welcomes the commitments by Australia, Canada, the European Union, Japan, and the United Kingdom that they will also take similarly forceful actions to hold Russia accountable – demonstrating the strength of our partnerships and deepening the impact on Russia more than any action we could have taken alone. This follows our joint action earlier this week to impose a first tranche of severe sanctions on Russia.

As a result of Putin’s war of choice, Russia will face immediate and intense pressure on its economy, and massive costs from its isolation from the global financial system, global trade, and cutting-edge technology. This includes cutting off Russia’s largest bank from the U.S. financial system – a significant blow to its ability to function and process global trade. It also includes full blocking sanctions on Russia’s second largest bank – freezing any of its assets touching the U.S. financial system.  Russia’s ability to access global markets, attract investment, and utilize the U.S. dollar will be devastated.

Russia’s economy has already faced intensified pressure in recent weeks; just today its stock market sunk to its lowest level in four and a half years, and the ruble weakened beyond its weakest daily settlement price on record – before additional sanctions were even imposed. With these new stringent measures, these pressures will further accumulate and suppress Russia’s economic growth, increase its borrowing costs, raise inflation, intensify capital outflows, and erode its industrial base. The United States and our Allies and partners are unified and will continue to impose costs, forcing Putin to look to other countries that cannot replicate the financial and technology strengths of Western markets.
Today, the United States carried out the following actions:

  • Severing the connection to the U.S. financial system for Russia’s largest financial institution, Sberbank, including 25 subsidiaries, by imposing correspondent and payable-through account sanctions. This action will restrict Sberbank’s access to transactions made in the dollar. Sberbank is the largest bank in Russia, holds nearly one-third of the overall Russian banking sector’s assets, is heavily connected to the global financial system, and is systemically critical to the Russian financial system.
     
  • Full blocking sanctions on Russia’s second largest financial institution, VTB Bank (VTB), including 20 subsidiaries. This action will freeze any of VTB’s assets touching the U.S financial system and prohibit U.S. persons from dealing with them. VTB holds nearly one-fifth of the overall Russian banking sector’s assets, is heavily exposed to the U.S. and western financial systems, and is systemically critical to the Russian financial system.
     
  • Full blocking sanctions on three other major Russian financial institutions: Bank Otkritie, Sovcombank OJSC, and Novikombank- and 34 subsidiaries. These sanctions freeze any of these institutions’ assets touching the U.S financial system and prohibit U.S. persons from dealing with them. These financial institutions play a significant a role in the Russian economy.
     
  • New debt and equity restrictions on thirteen of the most critical major Russian enterprises and entities. This includes restrictions on all transactions in, provision of financing for, and other dealings in new debt of greater than 14 days maturity and new equity issued by thirteen Russian state-owned enterprises and entities:  Sberbank, AlfaBank, Credit Bank of Moscow, Gazprombank, Russian Agricultural Bank, Gazprom, Gazprom Neft, Transneft, Rostelecom, RusHydro, Alrosa, Sovcomflot, and Russian Railways. These entities, including companies critical to the Russian economy with estimated assets of nearly $1.4 trillion, will not be able to raise money through the U.S. market — a key source of capital and revenue generation, which limits the Kremlin’s ability to raise money for its activity.
     
  • Additional full blocking sanctions on Russian elites and their family members: Sergei Ivanov (and his son, Sergei), Andrey Patrushev (and his son Nikolai), Igor Sechin (and his son Ivan), Andrey Puchkov, Yuriy Solviev (and two real estate companies he owns), Galina Ulyutina, and Alexander Vedyakhin. This action includes individuals who have enriched themselves at the expense of the Russian state, and have elevated their family members into some of the highest position of powers in the country. It also includes financial figures who sit atop Russia’s largest financial institutions and are responsible for providing the resources necessary to support Putin’s invasion of Ukraine. This action follows up on yesterday’s action targeting Russian elites and their family members and cuts them off from the U.S. financial system, freezes any assets they hold in the United States and blocks their travel to the United States.
     
  • Costs on Belarus for supporting a further invasion of Ukraine by sanctioning 24 Belarusian individuals and entities, including targeting Belarus’ military and financial capabilities by sanctioning two significant Belarusian state-owned banks, nine defense firms, and seven regime-connected official and elites. We call on Belarus to withdraw its support for Russian aggression in Ukraine.
     
  • Sweeping restrictions on Russia’s military to strike a blow to Putin’s military and strategic ambitions.  This includes measures against military end users, including the Russian Ministry of Defense. Exports of nearly all U.S. items and items produced in foreign countries using certain U.S.-origin software, technology, or equipment will be restricted to targeted military end users. These comprehensive restrictions apply to the Russian Ministry of Defense, including the Armed Forces of Russia, wherever located.
     
  • Russia-wide restrictions to choke off Russia’s import of technological goods critical to a diversified economy and Putin’s ability to project power. This includes Russia-wide denial of exports of sensitive technology, primarily targeting the Russian defense, aviation, and maritime sectors to cut off Russia’s access to cutting-edge technology. In addition to sweeping restrictions on the Russian-defense sector, the United States government will impose Russia-wide restrictions on sensitive U.S. technologies produced in foreign countries using U.S.-origin software, technology, or equipment. This includes Russia-wide restrictions on semiconductors, telecommunication, encryption security, lasers, sensors, navigation, avionics and maritime technologies. These severe and sustained controls will cut off Russia’s access to cutting edge technology.
     
  • Historical multilateral cooperation that serves as a force multiplier in restricting more than $50 billion in key inputs to Russia- impacting far more than that in Russia’s production. As a result of this multilateral coordination, we will provide an exemption for other countries that adopt equally stringent measures. Countries that adopt substantially similar export restrictions are exempted from new U.S. licensing requirements for items produced in their countries. The European Union, Australia, Japan, Canada, New Zealand and the United Kingdom, have already communicated their plans for parallel actions. This unprecedented coordination significantly expands the scope of restrictions on Russia. Further engagement with Allies and partners will continue to maximize the impact on Russia’s military capabilities.

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Press Releases

United States Acts in Tandem with Partners and Allies to Maximize Consequences for Russia, and in Show of Unity Against Invasion of a Sovereign State

Top Ten Russian Financial Institutions Now Under U.S Restrictions; U.S. Ready to Impose Additional Major Costs

WASHINGTONThe United States took significant and unprecedented action to respond to Russia’s further invasion of Ukraine by imposing severe economic costs that will have both immediate and long-term effects on the Russian economy and financial system. The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) today imposed expansive economic measures, in partnership with allies and partners, that target the core infrastructure of the Russian financial system — including all of Russia’s largest financial institutions and the ability of state-owned and private entities to raise capital — and further bars Russia from the global financial system. The actions also target nearly 80 percent of all banking assets in Russia and will have a deep and long-lasting effect on the Russian economy and financial system.

Building off of President Biden’s initial sanctions announcement this week, today Treasury is taking action against Russia’s top financial institutions, including sanctioning by far Russia’s two largest banks and almost 90 financial institution subsidiaries around the world. Treasury is also sanctioning additional Russian elites and their family members and imposing additional new prohibitions related to new debt and equity of major Russian state-owned enterprises and large privately owned financial institutions. This will fundamentally imperil Russia’s ability to raise capital key to its acts of aggression. These actions are specifically designed to impose immediate costs and disrupt and degrade future economic activity, isolate Russia from international finance and commerce, and degrade the Kremlin’s future ability to project power.

“Treasury is taking serious and unprecedented action to deliver swift and severe consequences to the Kremlin and significantly impair their ability to use the Russian economy and financial system to further their malign activity,” said Secretary of the Treasury Janet L. Yellen. “Our actions, taken in coordination with partners and allies, will degrade Russia’s ability to project power and threaten the peace and stability of Europe. We are united in our efforts to hold Russia accountable for its further invasion of Ukraine while mitigating impacts to Americans and our partners. If necessary, we are prepared to impose further costs on Russia in response to its egregious actions.”

Russia’s large financial services sector is heavily dominated by state-owned actors that rely on the U.S. financial system to conduct their business activities both within Russia and internationally. The sanctions the United States is imposing today cut off major parts of the Russian financial system and economy from access to this important financial infrastructure and the U.S. dollar more broadly.

The United States consulted closely with partners to tailor the economic costs of these actions to weigh most heavily on the Government of the Russian Federation (GoR) and its economy while mitigating impacts to America and its allies. Treasury’s sustained financial diplomacy over several months, on a near daily basis with partners and allies and at every level, has strengthened a unity of purpose, resolve, and technical coordination to deliver a broad array of impactful measures that will be felt deeply in Russia.

Today’s actions were taken pursuant to Executive Order (E.O.) 14024, which authorizes sanctions against Russia for its harmful foreign activities, including violating core principles of international law such as respect for the territorial integrity of sovereign states.

MAJOR ECONOMIC ACTIONS

Targeting Russia’s Two Largest Financial Institutions

Treasury is taking unprecedented action against Russia’s two largest financial institutions, Public Joint Stock Company Sberbank of Russia (Sberbank)and VTB Bank Public Joint Stock Company (VTB Bank), drastically altering their fundamental ability to operate. On a daily basis, Russian financial institutions conduct about $46 billion worth of foreign exchange transactions globally, 80 percent of which are in U.S. dollars. The vast majority of those transactions will now be disrupted. By cutting off Russia’s two largest banks — which combined make up more than half of the total banking system in Russia by asset value — from processing payments through the U.S. financial system. The Russian financial institutions subject to today’s action can no longer benefit from the remarkable reach, efficiency, and security of the U.S. financial system.

Correspondent and Payable-Through Account Sanctions on Sberbank

Today Treasury is imposing correspondent and payable-through account sanctions on Sberbank. Sberbank is uniquely important to the Russian economy, holding about a third of all bank assets in Russia. Sberbank is the largest financial institution in Russia and is majority-owned by the GoR. It holds the largest market share of savings deposits in the country, is the main creditor of the Russian economy, and is deemed by the GoR to be a systemically important financial institution. Within 30 days, OFAC is requiring all U.S. financial institutions to close any Sberbank correspondent or payable-through accounts and to reject any future transactions involving Sberbank or its foreign financial institution subsidiaries. Payments that Sberbank attempts to process in U.S. dollars for its clients — with examples ranging from to technology to transportation — will be disrupted and rejected once the payment hits a U.S. financial institution.

To implement sanctions on Sberbank, OFAC issued Directive 2 under E.O. 14024, “Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions” (the “Russia-related CAPTA Directive”). This directive prohibits U.S. financial institutions from: (i) the opening or maintaining of a correspondent account or payable-through account for or on behalf of any entity determined to be subject to the prohibitions of the Russia-related CAPTA Directive, or their property or interests in property; and (ii) the processing of transactions involving any such entities determined to be subject to the Russia-related CAPTA Directive, or their property or interests in property. Accordingly, U.S. financial institutions must reject such transactions unless exempt or authorized by OFAC.

Pursuant to Directive 2 under E.O. 14024, Sberbank and 25 Sberbank foreign financial institution subsidiaries that are 50 percent or more owned, directly or indirectly, by Sberbank were identified in Annex 1 to the Russia-related CAPTA Directive. These subsidiaries include banks, trusts, insurance companies, and other financial companies located in Russia and six other countries.

Sberbank and other affiliated entities determined to be subject to the Russia-related CAPTA Directive have been added to OFAC’s List of Foreign Financial Institutions Subject to Correspondent Account or Payable-Through Account Sanctions (CAPTA List), a reference tool that provides actual notice of OFAC actions with respect to foreign financial institutions for which the opening or maintaining of a correspondent account or a payable-through account in the United States is prohibited or subject to one or more strict conditions. All foreign financial institutions owned 50 percent or more, directly or indirectly, by Sberbank are covered by the prohibitions of the Russia-related CAPTA Directive, even if not identified on OFAC’s CAPTA List.

The prohibitions of the Russia-related CAPTA Directive take effect beginning at 12:01 a.m. eastern daylight time on March 26, 2022. Accordingly, by 12:01 a.m. eastern daylight time on March 26, 2022, U.S. financial institutions must have closed any correspondent or payable-through account maintained for Sberbank all other entities listed in Annex 1 to the Russia-related CAPTA Directive, and all foreign financial institutions owned 50 percent or more by the foregoing. In addition, after 12:01 a.m. eastern daylight time on March 26, 2022, U.S. financial institutions may not process transactions involving those institutions and must reject such transactions, unless exempt or authorized by OFAC.

Full Blocking Sanctions on VTB

OFAC has imposed full blocking sanctions on VTB Bank, Russia’s second-largest financial institution, which holds nearly 20 percent of banking assets in Russia. VTB Bank is majority-owned by the GoR, which deems it to be a systemically important financial institution. This will sever a critical artery of Russia’s financial system. By imposing these sanctions, assets held in U.S. financial institutions will be instantly frozen and inaccessible to the Kremlin. This is one of the largest financial institutions Treasury has ever blocked and sends an unmistakable signal that the United States is following through on its promise of delivering severe economic costs.

VTB Bank was designated pursuant to E.O. 14024 for being owned or controlled by, or for having acted or purported to act for or on behalf of, directly or indirectly, the GoR, and for operating or having operated in the financial services sector of the Russian Federation economy. In addition, 20 VTB Bank subsidiaries were designated pursuant to E.O. 14024 for being owned or controlled by, directly or indirectly, VTB Bank. These subsidiaries include banks, holding companies, and other financial companies located in Russia and eight other countries. All entities owned 50 percent or more, directly or indirectly, by VTB Bank are subject to blocking, even if not identified by OFAC.

Blocking Other Major Russian Financial Institutions

OFAC has also imposed blocking sanctions on three additional major Russian financial institutions: Otkritie, Novikom, and Sovcom. These three financial institutions play significant roles in the Russian economy, holding combined assets worth $80 billion. These designations further restrict the Russian financial services sector and greatly diminish the ability of other critical Russian economic sectors from accessing global markets, attracting investment, and utilizing the U.S. dollar.

Public Joint Stock Company Bank Financial Corporation Otkritie (Otkritie) is deemed by the GoR to be a systemically important Russian state-owned credit institution and is Russia’s seventh largest financial institution. Otkritie was designated pursuant to E.O. 14024 for being owned or controlled by, or for having acted or purported to act for or on behalf of, directly or indirectly, the GoR, and for operating or having operated in the financial services sector of the Russian Federation economy.

In addition, 12 Otkritie subsidiaries were designated today pursuant to E.O. 14024 for being owned or controlled by, or for having acted or purported to act for or on behalf of, directly or indirectly, Otkritie. The 12 Otkritie subsidiaries designated today include an insurance company, a bank, and other financial services companies in Russia and Cyprus. All entities owned 50 percent or more, directly or indirectly, by Otkritie are subject to blocking under E.O. 14024, even if not identified by OFAC.

Open Joint Stock Company Sovcombank (Sovcombank) is the third largest privately owned financial institution in Russia by total assets, and Russia’s ninth largest bank overall. The GoR identifies it as a systemically important Russian financial institution. Sovcombank was designated pursuant to E.O. 14024 for operating or having operated in the financial services sector of the Russian Federation economy.

In addition, 22 Sovcombank subsidiaries were designated today pursuant to E.O. 14024 for being owned or controlled by, or for having acted or purported to act for or on behalf of, directly or indirectly, Sovcombank. The 22 Sovcombank subsidiaries designated today include a variety of financial services companies in Russia and Cyprus. All entities owned 50 percent or more, directly or indirectly, by Sovcombank are subject to blocking under E.O. 14024, even if not identified by OFAC.

Joint Stock Commercial Bank Novikombank (Novikombank) is state-owned and among the 50 largest financial institutions in Russia. Novikombank primarily operates in the Russian defense sector and serves as the core financial institution for Russian defense company Rostec, which fully owns the bank. Novikombank was designated pursuant to E.O. 14024 for operating or having operated in the financial services sector of the Russian Federation economy. Prior to today’s action, Novikombank was subject to certain debt-related restrictions pursuant to Directive 3 under E.O. 13662 but is now blocked. Novikombank’s parent company, Rostec, remains subject to certain debt-related restrictions pursuant to Directive 3 under E.O. 13662.

Debt and Equity Prohibitions Against Major State-Owned and Private Entities

In a move to limit Russia’s ability to finance its invasion against Ukraine or other priorities of President Putin, OFAC expanded Russia-related debt and equity restrictions to additional key aspects of Russia’s economy. To implement this action, OFAC issued Directive 3 under E.O. 14024, “Prohibitions Related to New Debt and Equity of Certain Russia-related Entities” (the “Russia-related Entities Directive”) to prohibit transactions and dealings by U.S. persons or within the United States in new debt of longer than 14 days maturity and new equity of Russian state-owned enterprises, entities that operate in the financial services sector of the Russian Federation economy, and other entities determined to be subject to the prohibitions in this directive.

These 13 major firms, which are listed in Annex 1 to the Russia-related Entities Directive, include companies critical to the Russian economy and six of Russia’s largest financial institutions. They are now heavily restricted from raising money through the U.S. market — a key source of capital and revenue generation, which limits the Kremlin’s ability to raise money for its malign activity — including to support the further invasion of Ukraine.

Today’s action pursuant to the Russia-related Entities Directive further expands the number of Russian entities subject to prohibitions related to new debt and equity. This includes 13 entities with outstanding debt issuances, six of which are also subject to certain debt or additional restrictions pursuant to directives under E.O. 13662.

Pursuant to E.O. 14024, OFAC identified the following 11 Russian entities as being owned or controlled by, or having acted or purposed to act for or on behalf of, directly or indirectly, the GoR:

  • Sberbank is Russia’s largest financial institution. Today, Sberbank was also identified as subject to the Russia-related CAPTA Directive.
  • Gazprombank Joint Stock Company is Russia’s third-largest financial institution and is closely affiliated with the energy sector.
  • Joint Stock Company Russian Agricultural Bank is Russia’s fifth-largest financial institution and closely affiliated with the agricultural sector.
  • Public Joint Stock Company Gazprom is the world’s largest natural gas company.
  • Public Joint Stock Company Gazprom Neft is one of Russia’s largest oil producers and refiners.
  • Public Joint Stock Company Transneft (Transneft) manages Russia’s network of petroleum-related pipelines.
  • Public Joint Stock Company Rostelecom is Russia’s largest telecommunications company.
  • Public Joint Stock Company RusHydro is a hydroelectricity company and one of Russia’s largest power companies.
  • Public Joint Stock Company Alrosa is the world’s largest diamond mining company, responsible for 90 percent of Russia’s diamond mining capacity, which accounts for 28 percent globally.
  • Joint Stock Company Sovcomflot is Russia’s largest maritime and freight shipping company.
  • Open Joint Stock Company Russian Railways is one of the world’s largest railroad companies.

Pursuant to E.O. 14024, OFAC identified the following three Russian entities for operating or having operated in the financial services sector of the Russian Federation economy:

  • Joint Stock Company Alfa-Bank is Russia’s largest privately owned financial institution, and Russia’s fourth-largest financial institution overall.
  • Credit Bank of Moscow Public Joint Stock Company is Russia’s largest non-state public bank and Russia’s sixth-largest financial institution.
  • Sberbank, which is described above.

General Licenses

To ensure that these sanctions and prohibitions have an impact on the intended targets and to minimize unintended consequences on third parties, OFAC has also issued several general licenses in connection with these actions. In particular, payments for energy are from production to consumption. The sanctions and license package has been constructed to account for the challenges high energy prices pose to average citizens and doesn’t prevent banks from processing payments for them.

Specifically, OFAC issued eight general licenses authorizing certain transactions related to:

  • international organizations and entities;
  • agricultural and medical commodities and the COVID-19 pandemic;
  • overflight and emergency landings;
  • energy;
  • dealings in certain debt or equity;
  • derivative contracts;
  • the wind down of transactions involving certain blocked persons; and
  • the rejection of transactions involving certain blocked persons.

To provide further guidance on these authorizations and today’s action, OFAC also issued extensive public guidance in the form of Frequently Asked Questions (FAQs).

NEW ACTIONS TARGETING RUSSIAN ELITES

Families Close to Putin

Elites close to Putin continue to leverage their proximity to the Russian President to pillage the Russian state, enrich themselves, and elevate their family members into some of the highest positions of power in the country at the expense of the Russian people. Sanctioned oligarchs and powerful Russian elites have used family members to move assets and to conceal their immense wealth. The following designations target influential Russians in Putin’s inner circle and in elite positions of power within the Russian state. Many of these individuals are believed to participate in, or benefit from, the Russian regime’s kleptocracy, along with their family members. Many serve in leadership roles of companies designated or identified today.

Sergei Sergeevich Ivanov, son of Sergei Borisovich Ivanov

Sergei Borisovich Ivanov (Sergei B. Ivanov) is the Special Presidential Representative for Environmental Protection, Ecology, and Transport. Sergei B. Ivanov is reportedly one of Putin’s closest allies and previously served as the Chief of Staff of the Presidential Executive Office, Deputy Prime Minister, and Defense Minister of Russia. He is also a permanent member of the Security Council of the Russian Federation. Sergei B. Ivanov was previously designated in March 2014 for being an official of the GoR. Sergei Ivanov’s son, Sergei Sergeevich Ivanov (Sergei S. Ivanov), is the current CEO of Russian state-owned diamond mining company Alrosa and a board member of Gazprombank.

OFAC redesignated Sergei B. Ivanov and designated his son Sergei S. Ivanov pursuant to E.O. 14024 for being or having been leaders, officials, senior executive officers, or members of the board of directors of the GoR. Sergei S. Ivanov was also designated pursuant to E.O. 14024 for being the spouse or adult child of Sergei B. Ivanov, a person whose property or interests in property are blocked for being or having been a leader, official, senior executive officer, or member of the board of directors of the GoR.

Andrey Patrushev, son of Nikolai Platonovich Patrushev

Nikolai Platonovich Patrushev (Nikolai Patrushev) is the Secretary of the Russian Federation Security Council and is reported to be a longtime close associate of Putin. Nikolai Patrushev was previously designated in April 2018 for being an official of the GoR. Patrushev’s son, Andrey Patrushev, served in leadership roles at Gazprom Neft and is employed in Russia’s energy sector.

OFAC redesignated Nikolai Patrushev and designated his son Andrey Patrushev pursuant to E.O. 14024 for being or having been leaders, officials, senior executive officers, or members of the board of directors of the GoR. Andrey Patrushev was also designated pursuant to E.O. 14024 for being the spouse or adult child of Nikolai Patrushev, a person whose property or interests in property are blocked for being or having been a leader, official, senior executive officer, or member of the board of directors of the GoR.

Ivan Igorevich Sechin, son of Igor Ivanovich Sechin

Igor Ivanovich Sechin (Igor Sechin) is the Chief Executive Officer (CEO), Chairman of the Management Board, and Deputy Chairman of the Board of Directors of Rosneft, one of the world’s largest publicly traded oil companies. Igor Sechin was formerly the Deputy Prime Minister of the Russian Federation from 2008 until 2012 and is reportedly a close ally of Putin. Igor Sechin was previously designated in April 2014 pursuant to E.O. 13661 for being an official of the GoR. Igor Sechin’s son, Ivan Igorevich Sechin (Ivan Sechin), is reportedly a deputy head of a department at Rosneft.

OFAC redesignated Igor Sechin pursuant to E.O. 14024 for being or having been a leader, official, senior executive officer, or member of the board of directors of the GoR. Ivan Sechin was designated pursuant to E.O. 14024 for being the spouse or adult child of Igor Sechin, a person whose property or interests in property are blocked for being or having been a leader, official, senior executive officer, or member of the board of directors of the GoR.

Financial Sector Elites

Senior executives at state-owned banks, like Kremlin-linked elites, take advantage of their closeness to the Russian power vertical to advance the interests of the Russian state while maintaining an extravagant standard of living.

Alexander Aleksandrovich Vedyakhin (Vedyakhin) is First Deputy Chairman of the Executive Board of Sberbank. OFAC designated Vedyakhin pursuant to E.O. 14024 for being or having been a leader, official, senior executive officer, or member of the board of directors of the GoR.

Andrey Sergeyevich Puchkov (Puchkov) and Yuriy Alekseyevich Soloviev (Soloviev) are two high-ranking VTB Bank executives who work closely with VTB Bank chief executive Andrei Kostin, whom OFAC designated in April 2018 pursuant to E.O. 13661. Puchkov also has other business interests beyond VTB, including Moscow-based real estate companies Limited Liability Company Atlant S and Limited Liability Company Inspira Invest A.

Soloviev’s wife, Galina Olegovna Ulyutina (Ulyutina), was previously implicated in a golden passport scheme.

OFAC designated Puchkov and Soloviev pursuant to E.O. 14024 for being or having been leaders, officials, senior executive officers, or members of the board of directors of the GoR.

Limited Liability Company Atlant S and Limited Liability Company Inspira Invest A were designated pursuant to E.O. 14024 for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Puchkov.

Ulyutina was designated pursuant to E.O. 14024 for being the spouse or adult child of Soloviev, a person whose property and interests in property are blocked pursuant to E.O. 14024.

For identifying information on the individuals and entities sanctioned today, click here.

For Treasury’s concurrent designation of critical Belarusian state-owned banks, defense firms, and regime-connected individuals, click here.

For the White House fact sheet about the Biden Administration’s actions today, click here.

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Subsidiaries of Russian Financial Institutions Sanctioned on February 24, 2022Pursuant to E.O. 14024

The following Sberbank subsidiaries are subject to the Russia-related CAPTA Directive:

  1. Subsidiary Bank Sberbank of Russia Joint Stock Company is a bank located in Kazakhstan.
  2. Joint Stock Company Sberbank is a bank located in Ukraine.
  3. Open Joint Stock Company BPS-Sberbank is a bank located Belarus.
  4. IKS Joint Stock Company is a real estate, security brokering, fund management, depository credit intermediation, as well as other activities auxiliary to financial intermediation, company located in Russia.
  5. Joint Stock Company Sberbank Leasing is a bank located in Russia.
  6. Limited Liability Company Sberbank Capital is a mutual and pension fund or trust located in Russia.
  7. Joint Stock Company Sberbank Automated Trade System is a vendor of financial securities on electronic trading platforms located in Russia.
  8. Limited Liability Company Promising Investments is a financial company located in Russia.
  9. Limited Liability Company Sberbank Financial Company is a financial company located in Russia.
  10. Limited Liability Company Sberbank Investments is a financial company located in Russia.
  11. Sberbank Europe AG is a bank located in Austria.
  12. Insurance Company Sberbank Life Insurance Limited Liability Company is an insurance company located in Russia.
  13. SB Securities SA is a mutual and pension fund or trust located in Luxembourg.
  14. Joint Stock Company Sberbank Private Pension Fund is a mutual and pension fund or trust located in Russia.
  15. Limited Liability Company Sberbank Insurance Broker is a financial and insurance company located in Russia.
  16. Insurance Company Sberbank Insurance Limited Liability Company is an insurance company located in Russia.
  17. Limited Liability Company Sberbank CIB Holding is a financial company located in Russia.
  18. Limited Liability Company Sberbank Factoring is a financial company located in Russia
  19. Joint Stock Company Raschetniye Resheniya is a bank located in Russia.
  20. Vydayushchiesya Kredity Microcredit Company Limited Liability Company is a financial and insurance company in Russia.
  21. Tekhnologii Kreditovaniya Limited Liability Company is an Internet-based financial activities company located in Russia.
  22. Arimero Holding Limited is a financial, insurance, and holding company located in Cyprus.
  23. Setelem Bank Limited Liability Company is a bank located in Russia.
  24. Limited Liability Company Yoomoney is a bank located in Russia.
  25. Limited Liability Company Market Fund Administration is a mutual and pension fund or trust located in Russia.

 

The property and interests in property of the following VTB Bank subsidiaries are blocked:

  1. BM Bank Joint Stock Company is a bank located in Russia.
  2. VTB Capital Holding Closed Joint Stock Company is a holding company located in Russia.
  3. NPF VTB Pension Fund Joint Stock Company is a non-state pension fund company located in Russia.
  4. VTB Factoring Limited is a finance and factoring company located in Russia.
  5. Bank VTB Kazakhstan Joint Stock Company is a bank located in Kazakhstan.
  6. VTB Bank Armenia Closed Joint Stock Company is a bank located in Armenia.
  7. VTB Bank Azerbaijan Open Joint Stock Company is a bank located in Azerbaijan.
  8. VTB Bank Belarus Closed Joint Stock Company is a bank located in Belarus.
  9. VTB Bank Georgia Joint Stock Company is a bank located in Georgia.
  10. Banco VTB Africa SA is a bank located in Angola.
  11. VTB Specialized Depository Closed Joint Stock Company is an intermediation and financial company located in Russia.
  12. VTB Pension Administrator Limited is a holding company located in Russia.
  13. Limited Liability Company VTB DC is a financial and management consulting company located in Russia.
  14. VTB Registrar Closed Joint Stock Company is a financial company located in Russia.
  15. Business Finance Limited Liability Company is a security brokerage and financial leasing company located in Russia.
  16. West Siberian Commercial Bank Public Joint Stock Company is a bank located in Russia.
  17. Joint-Stock Company Sarovbusinessbank is a bank located in Russia.
  18. Vietnam-Russia Joint Venture Bank is a bank located in Vietnam.
  19. VTB Bank Europe SE is a bank located in Germany.
  20. Obshchestvo S Ogranichennoi Otvetstvennostyu VTB Foreks is a financial company located in Russia.

 

 

The property and interests in property of the following Otkritie subsidiaries are blocked:

  1. Public Joint Stock Company Insurance Company Rosgosstrakh is an insurance company located in Russia.
  2. Otkritie Ltd Group is a financial company located in Cyprus.
  3. OOO Navigator Asset Management is a financial company located in Russia.
  4. OOO Otkritie Asset Management is a financial company located in Russia.
  5. Otkritie Broker Group is a financial company located in Russia.
  6. OOO Tamozhennaya Karta is a financial company located in Russia.
  7. OOO Otkritie Factoring is a financial company located in Russia.
  8. OOO RGS Holding is a financial company located in Russia.
  9. OOO Otkritie Capital is a financial company located in Russia.
  10. Otkritie Capital Cyprus Limited is a financial company located in Cyprus.
  11. NPF Otkritie Group is a non-state pension fund located in Russia.
  12. PAO Rosgosstrakh Bank is a bank located in Russia.

 

The property and interests in property of the following Sovcombank subsidiaries are blocked:

  1. Aktsionernoe Obshchestvo Fintender is a financial technology company located in Russia.
  2. Bank National Factoring Company Joint Stock Company is a financial institution located in Russia.
  3. Sovcombank Factoring Limited Liability Company is a financial company located in Russia.
  4. BEST2PAY Limited is a financial company located in Russia.
  5. GMCS Management Limited Liability Company is a financial management company located in Russia.
  6. Septem Capital Limited Liability Company is an investment company located in Russia.
  7. Joint Stock Company Sovcombank Life is an insurance company located in Russia.
  8. Limited Liability Company Ozon Bank is a financial institution located in Russia.
  9. Mobilnye Platezhi Limited Liability Company is a financial technology company located in Russia.
  10. Ruskonsalt is a company located in Russia.
  11. Sollers-Finance Limited Liability Company is a financial company located in Russia.
  12. Sovcombank Asset Management Limited Liability Company is a financial management company located in Russia.
  13. Sovcombank Securities Limited is a financial company located in Cyprus.
  14. Sovcombank Technologies Limited Liability Company is a financial technology company located in Russia.
  15. Sovkom Faktoring is a company located in Russia.
  16. Sovkom Lizing is a leasing company located in Russia.
  17. Sovcomcard Limited Liability Company is a financial company located in Russia.
  18. Tsifrovye Tekhnologii Budushchego Limited Liability Company is a financial technology company located in Russia.
  19. USM Limited Liability Company is a financial company located in Russia.
  20. Aktsionernoe Obshchestvo Sovkombank Strakhovanie is a financial company located in Russia.
  21. Public Joint Stock Company KB Vostochny is a financial company located in Russia.
  22. Aktsionernoe Obshchestvo Rts-Kholding is a financial management company located in Russia.

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