OFAC Sanctions Russian Organizations and Individuals Involved in Ukraine War
The Office of Foreign Assets Control has designated 22 individuals and two entities connected with Russia's war in Ukraine. The designated individuals have furthered Russia's objectives in Ukraine, both before and during the invasion, OFAC said in a Sept. 15 notice. “Today we’re taking steps to further degrade Russia’s ability to rebuild its military, hold perpetrators of violence accountable, and further financially isolate Putin," Treasury Secretary Janet Yellen said in a news release.
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Sanctioned individuals include financial officials of NSPK, a bank that operates Russia's Mir payment card network, Russia’s central securities depository, National Clearing Center, and Deposit Insurance Agency, a state-owned entity that the Kremlin uses for liquidating financial institutions and accessing foreign assets.
Other sanctions target Maria Alexeyevna Lvova-Belova, Russia’s presidential commissioner for children’s rights, who allegedly led Russia’s efforts to deport thousands of Ukrainian children to Russia, including the forced adoption and “patriotic education” of Ukrainian children. The designations also included new sanctions on Ramzan Kadyrov, the leader of Russia’s Republic of Chechnya, and his immediate family. Kadyrov is designated for his role in recruiting and supplying Chechnyan fighters in Ukraine.
OFAC also designated Task Force Rusich and its leaders, Alexey Milchakov and Yan Petrovskiy. According to OFAC, Rusich is a neo-Nazi paramilitary group that has operated with the Russian military in Ukraine. In 2015, Rusich mercenaries were accused of committing atrocities against deceased and captured Ukrainian soldiers. Rusich is associated with previously designated groups PMC Wagner and the Union of Donbas Volunteers.
The agency also issued Russia-related general licenses 51 and 52. GL 51 allows transactions necessary for winding down of operations involving the Akvarius LLC Group of Companies (Aquarius). Wind-down transactions that are otherwise prohibited by Executive Order 14024, are authorized through 12:01 a.m. EDT Oct. 15. GL 52 allows journalists and broadcast or technical personnel to engage in transactions necessary for journalistic activities or to the operation of a news bureau, which are overwise prohibited by EO14024
OFAC updated its FAQs in relation to the designations and the new license.
FAQ 1080 explains that accounts held at any blocked Russian financial institutions generally are considered blocked property, unless exempt. General License 50 allows persons with accounts blocked under EO 14024 to unblock and transfer funds to an account at a non-designated financial institution. Individuals who have filed a blocking report with OFAC and are availing themselves of GL 50 must file an unblocking report with OFAC within 10 business days of the unblocking.
FAQ 1081 explains that individuals using GL 50 don't need to provide official documentation proving they have closed their account at the blocked Russian financial institution.
FAQ 1082 explains that non-U.S. financial institutions entering into new agreements with NSPK risk supporting Russia’s efforts to evade U.S. sanctions and therefore risk OFAC blocking sanctions.