Treasury, Commerce, State and the UK's Foreign Office launched a coordinated expansion of sanctions on the Russian military-industrial complex, as well as the personal holdings and advisors of a prominent oligarch.
Additionally, the State Department is sanctioning two Russian entities that support the militarization and indoctrination of schoolchildren.
Treasury's Office of Foreign Assets Control (OFAC) and UK officials are targeting the facilitation network of Alisher Usmanov, one of Russia's wealthiest billionaires, who is subject to sanctions in multiple jurisdictions.
The UK actions against the same individuals drew attention to the prominent role of Roman Amramovich, whose billions in trust were cleverly reorganized shortly before sanctions were imposed.
OFAC is designating 25 individuals and 29 entities with touchpoints in 20 jurisdictions.
The U.S. Department of State is concurrently designating several entities operating in the defense sector of the Russian Federation economy, entities supporting Russia's war against Ukraine, and additional entities associated with Russia's State Atomic Energy Corporation.
Usmanov holds significant interests in the metals and mining, telecommunications, and information technology sectors. In addition to being sanctioned by the United States, he has also been sanctioned by Australia, Canada, the European Union, Japan, New Zealand, Switzerland, and the United Kingdom.
A State Department [fact sheet] details the extent of Usmanov's network of entities and enablers, in addition to the over 80 entities sanctioned for their support of the Russian war effort.
OFAC's actions include revoking Russia-related General License 15, which had authorized transactions involving any entity owned 50 percent or more, directly or indirectly, by Usmanov that was not listed on OFAC's Specially Designated Nationals and Blocked Persons List. As a result, any entities that are owned, directly or indirectly, 50 percent or more by Usmanov are blocked, regardless of whether such entities are listed on the SDN List.
The Commerce Department’s Bureau of Industry and Security (BIS) has added 28 entities to its Entity List. The BIS is coordinating its actions with additional sanctions by the Departments of State and Treasury
The 28 entities added to the Entity List are divided into three categories. Five entries under China, two entries under Russia, and two entries under Turkey were added for attempting to evade export controls and acquiring or attempting to acquire US origin items in support of Russia's military and/or defense industrial base.
One entry each under the destinations of Malta, Spain, and Syria, and two entries under the destination of the UAE were added for coordinating flights that assisted in the transfer of Iranian unmanned aerial vehicles, personnel, and related equipment from Iran to Russia.
Sixteen entities under 17 designations were added for continuing to procure items on behalf of Russian parties already on the Entity List or on the US Department of the Treasury's SDN List.
In Conjunction with the Usmanov actions, OFAC issued General License 25C (GL 25C) to authorize transactions ordinarily incident and necessary to the receipt or transmission of telecommunications involving the Russian Federation that are prohibited by the Russian Harmful Foreign Activities Sanctions Regulations.
However, certain transactions related to Megafon PAO or Limited Liability Company Digital Invest, or any entity in which Megafon or Digital Invest owns, directly or indirectly, a 50 percent or greater interest, may not involve the Russian Federation and thus may not be authorized by GL 25C.
To ensure certain transactions related to telecommunications and internet-based communications involving the Covered Entities and Tajikistan or Uzbekistan can continue, OFAC issued General License 65 (GL 65). GL 65 authorizes all transactions prohibited by the RuHSR that are ordinarily incident and necessary to the receipt or transmission of telecommunications involving the Covered Entities and Tajikistan or Uzbekistan. It also authorizes the exportation or reexportation, sale, or supply, directly or indirectly, from the United States or by U.S. persons, wherever located, to the Covered Entities of services, software, hardware, or technology incident to the exchange of communications over the internet that is prohibited by the RuHSR.
It is important to note that GL 65 does not relieve persons from compliance with other federal laws, such as the export licensing requirements maintained by the Department of Commerce's Bureau of Industry and Security.
Treasury's Office of Foreign Assets Control (OFAC) is issuing Russia-related General License 62, "Authorizing the Wind Down of Transactions Involving Holdingovaya Kompaniya Metalloinvest AO, MegaFon PAO, Limited Liability Company USM Telecom, or Akkermann Cement Ca Limited Liability Company", General License 63, "Authorizing Transactions Related to Debt or Equity of, or Derivative Contracts Involving, Holdingovaya Kompaniya Metalloinvest AO," General License 64, "Authorizing Certain Transactions Involving Kommersant", and General License 65, "Authorizing Transactions Related to Telecommunications and Certain Internet-based Communications Involving MegaFon PAO or Digital Invest Limited Liability Company." OFAC is revoking Russia-related Russia-related General License 15, "Authorizing Transactions Involving Certain Blocked Entities Owned by Alisher Burhanovich Usmanov." OFAC is also issuing one Frequently Asked Questions (1122).
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