Publications

From Oligarch to SDN: New Designations Deepen Risks of Business with Russia

April 9, 2018 Advisory

On April 6, 2018, the Department of Treasury's Office of Foreign Assets Control ("OFAC") announced new Specially Designated National ("SDN") and Russian Sectoral Sanctions designations for a number of individuals and entities pursuant to its authority under Ukraine/Russia-related Executive Orders 13661 and 13662, the Syria Sanctions Regulations, and the Foreign Narcotics Kingpin Designation Act. In addition to these designations, OFAC issued General License 12 and General License 13, which authorize certain wind down and divestiture-related activities that would otherwise be prohibited as a result of the new designations.

A number of the designations announced on April 6 are directed at individuals who were previously identified by OFAC as Senior Political Figures or Oligarchs of the Russian Federation in its January 29, 2018 Report to Congress Pursuant to Section 241 of the Countering American's Adversaries Through Sanctions Act of 2017 Regarding Senior Foreign Political Figures and Oligarchs in the Russian Federation and Russian Parastatal Entities ("OFAC's Report to Congress"), as well as entities with which they are affiliated. While identification as a Russian Senior Political Figure or Oligarch did not immediately subject individuals to U.S. sanctions, suspicions that this listing could lead to sanctions designations in the future appears to be validated by OFAC's most recent designations. More than half of the individuals designated as SDNs on April 6 were previously identified in OFAC's Report to Congress, as follows:

Designations Associated with Russia/Ukraine Sanctions Program

April 6 Individual SDN Designations

Named Russian Oligarch or Senior Political Figure

Andrey Igorevich Akimov[1]

X

Vladimir Leonidovich Bogdanov

X

Oleg Vladimirovich Deripaska

X

Alexey Gennadyevich Dyumin

Mikhail Efimovich Fradkov

Sergei Fursenko

Oleg Govorun

X

Suleiman Abusaidovich Kerimov

X

Vladimir Alexandrovich Kolokoltsev

X

Konstantin Kosachev

Andrey Leonidovich Kostin

X

Alexey Borisovich Miller

X

Nikolai Platonovich Patrushev

X

Vladislav Matusovich Reznik

Igor Arkadyevich Rotenberg

Kirill Nikolaevich Shamalov

X

Evgeniy Mikhailovich Shkolov

X

Andrei Vladimirovich Skoch

X

Alexander Porfiryevich Torshin

Vladimir Vasilyevich Ustinov

X

Timur Samirovich Valiulin

Viktor Feliksovich Vekselberg

X

Alexander Alexandrovich Zharov

Viktor Vasiliyevich Zolotov

X

April 6 Entity Designations

OFAC Identified Affiliation

Agroholding Kuban
Basic Element Limited
B-Finance Ltd
EN+ Group PLC
GAZ Group
Russian Machines
JSC Eurosibenergo
United Company Rusal PLC

Oleg Vladimirovich Deripaska

Gazprom Burenie, OOO
NPV Engineering Open Joint Stock Company

Igor Arkadyevich Rotenberg

Ladoga Menedzhment, OOO

Kirill Nikolaevich Shamalov

Renova Group

Viktor Feliksovich Vekselberg

To read the full advisory, please click the PDF link below.


[1] Chairman of the Management Board of Gazprombank, which was previously designated as a Sectoral Sanctions Entity subject to Directive 1

Resources