FEBRUARY 21, 2022 SANCTIONS
On February 21, 2022 the Biden Administration issued an Executive Order (EO) relating to Donetsk and Luhansk People’s Republics (DNR and LNR) as “independent” states. To read the order follow this link: Executive Order on Blocking Property of Certain Persons and Prohibiting Certain Transactions With Respect to Continued Russian Efforts to Undermine the Sovereignty and Territorial Integrity of Ukraine | The White House
The February 21 EO prohibits:
- New investment in the DNR or LNR regions of Ukraine by a United States person, wherever located;
- The importation into the United States, directly or indirectly, of any goods, services, or technology from the so-called DNR or LNR regions of Ukraine;
- The exportation, re-exportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of any goods, services, or technology to the DNR or LNR regions;
- And any approval, financing, facilitation, or guarantee by a United States person, wherever located, of a transaction by a foreign person where the transaction by that foreign person would be covered by these prohibitions if performed by a United States person or within the United States.
The E.O. also provides authority to impose sanctions on persons determined:
- To operate or have operated since the date of the order in the DNR or LNR regions;
- To be or have been since the date of the order a leader, official, senior executive officer, or member of the board of directors of an entity operating in the DNR or LNR regions;
- To be owned or controlled by, or to have acted or purported to act for or on behalf of, directly or indirectly, any person whose property and interests in property are blocked pursuant to the order;
- Or to have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, any person whose property and interests in property are blocked pursuant to the order.
FEBRUARY 24, 2022 SANCTIONS
The US Treasury Department’s OFAC imposed additional sanctions on February 24, 2022 that target all of Russia’s largest financial institutions and are designed to hinder the ability of state-owned and private entities to raise capital and further bar Russia from the global financial system. The Treasury Department asserted that the action would affect nearly 80% of all Russian banking assets.
OFAC sanctioned Russia’s two largest banks: (i) Public Joint Stock Company Sberbank of Russia (Sberbank), (ii) VTB Bank Public Joint Stock Company (VTB Bank), and (iii) nearly 90 financial institution subsidiaries around the world.
Additional sanctions announcement: U.S. Treasury Announces Unprecedented & Expansive Sanctions Against Russia, Imposing Swift and Severe Economic Costs | U.S. Department of the Treasury
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”). correspondent_accounts_directive_2.pdf (treasury.gov)