Russia and Belarus sanctions update

Recently, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) has taken additional actions against Russia in response to its continued invasion of Ukraine. Specifically, OFAC:

• Issued guidance targeting persons, both inside and outside of Russia, who provide material support for sanctioned persons or sanctionable activity, particularly those that provide political or economic support for Russia’s illegal attempt to annex Ukrainian sovereign territory;
• Confirmed that, for now, transactions related to the sale of or transport of Russian-origin energy products are allowed, aside from the importation of such products into the United States, even as the US and the rest of the G7 intend to place a ban on services in support of the seaborne transportation of Russian oil by December 5;
• Updated the Specially Designated Nationals and Blocked Person (SDN) List by designating 14 persons in Russia’s military-industrial complex, including two international suppliers, three key leaders of Russia’s financial infrastructure, immediate family members of some senior Russian officials, and 278 members of Russia’s legislature for enabling Russia’s illegitimate referenda and attempt to annex sovereign Ukrainian territory.

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