Russia Sanctions
The sanctions imposed on Russia stem from actions that the international community has deemed violations of key principles of international law. These measures were implemented in response to conduct that raised serious concerns regarding compliance with international sanctions and human rights, as well as interference in the sovereign processes of other nations.
Why Russia Faced Sanctions?
Human Rights Violations
U.S. sanctions against Russian officials for gross human rights violations were imposed under the Global Magnitsky Human Rights Accountability Act (2016). This legislation grants the authority to sanction individuals involved in human rights abuses and corruption. The Act was enacted in response to the death of Sergei Magnitsky, a Russian lawyer who exposed large-scale corruption among Russian officials. Sanctions under this Act targeted high-ranking individuals such as Alexander Bastrykin, the Chairman of the Investigative Committee of the Russian Federation, who was implicated in the persecution of Magnitsky. Additionally, sanctions were applied in response to the assassination attempt on Alexei Navalny on August 20, 2020, and later his death in a Russian prison on February 16, 2024. Navalny had previously been poisoned with a nerve agent from the organophosphate group known as “Novichok.” This substance is banned under the Chemical Weapons Convention (1993), ratified by Russia on November 5, 1997. In response, the U.S. imposed sanctions under the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 and E.O 13818, which expands the Global Magnitsky Act’s reach. These actions also contravene Russia’s obligations under the Universal Declaration of Human Rights (1948) and the International Covenant on Civil and Political Rights (1966), which guarantee fundamental human rights such as the right to life, liberty, and personal security. The imposition of sanctions on individuals and entities involved in repression and human rights abuses underscores the U.S. commitment to holding accountable those who violate international norms and human rights.
Election Interference and Cyber Attacks
Regarding election interference and cyberattacks, Russia’s actions in 2016 became a primary basis for stringent U.S. sanctions. These cyberattacks, orchestrated by Russian state entities, including the Main Directorate of the General Staff of the Armed Forces of the Russian Federation (GRU), targeted the servers of the Democratic National Committee and sought to manipulate public opinion. These actions not only violate international norms but also U.S. law. Specifically, they breach the International Covenant on Civil and Political Rights (1966), particularly Article 25, which guarantees citizens the right to participate in the political process free from external interference. Legally, the GRU’s cyberattacks also violate U.S. Code Title 18, Section 1030 (Computer Fraud and Abuse Act – CFAA), which prohibits unauthorized access to computer systems, and U.S. Code Title 52, Section 30121 (Federal Election Campaign Act – FECA), which forbids foreign entities from interfering in U.S. elections. These actions led to sanctions against key figures, such as Yevgeny Prigozhin, and organizations, such as the Internet Research Agency (IRA), known for its disinformation campaigns. The sanctions were imposed under E.O 13694 (as amended by E.O 13757), which expands U.S. authority to sanction entities responsible for cyberattacks and interference in democratic processes.
Annexation of Crimea in 2014 and Full-Scale Invasion of Ukraine in 2022
The annexation of Crimea in 2014, support for armed conflict in eastern Ukraine, and the full-scale invasion in February 2022 constitute violations of Article 2(4) of the Charter of the United Nations (1945), signed by Russia on October 24, 1945, which prohibits the use of force or the threat of force against the territorial integrity and political independence of states. These actions also violate the Declaration of State Sovereignty of Ukraine (1990) and the Act of Declaration of Independence of Ukraine (1991), both of which affirmed Ukraine’s right to independent existence within internationally recognized borders. Furthermore, Russia breached the Budapest Memorandum on Security Assurances (1994), signed by Russia on December 5, 1994, specifically Articles 1 and 2, where it explicitly committed to respect Ukraine’s independence, sovereignty, and existing borders.
The Kremlin also disregarded the Final Act of the Conference on Security and Cooperation in Europe (1975), signed by Russia on August 1, 1975, known as the Helsinki Act, by violating Principles VI and VII, which establish the inviolability of borders and the obligation to respect state sovereignty. Another significant breach is the Treaty on Friendship, Cooperation, and Partnership between the Russian Federation and Ukraine (1997), signed by Russia on May 31, 1997, particularly Articles 2 and 3, wherein Russia pledged to respect Ukraine’s territorial integrity and political independence. These actions were unequivocally condemned in United Nations General Assembly Resolution 68/262 (2014), which Russia voted against on March 27, 2014, reaffirming Ukraine’s territorial integrity and rejecting the annexation of Crimea.
Moreover, Russia grossly violated the Geneva Convention Relative to the Protection of Civilian Persons in Time of War (Fourth Geneva Convention, 1949), signed by Ukraine and Russia on December 12, 1949, specifically Article 49(6), which prohibits the forcible transfer of population from occupied territories—a practice that occurred in Crimea. Furthermore, Russia’s actions in eastern Ukraine may be viewed as violations of the Convention on the Prevention and Punishment of the Crime of Genocide (1948), signed by Russia on December 16, 1949, particularly Articles II and III, given the devastating impact on the civilian population.
The Latest Sanctions on Russia
Recently, the United States has significantly intensified its sanctions regime against Russia, implementing new measures aimed at undermining its military and economic infrastructure. Among these recent sanctions are the prohibition on importing Russian uranium, the expansion of sanctions on key sectors of the economy, including financial and technological services, and the imposition of restrictions on the provision of IT services and cloud solutions. These measures include sanctions against more than 2,500 individuals and entities, including OFAC secondary sanctions targeting those involved in sanctions evasion and supporting Russia’s military-industrial complex, highlighting the comprehensive and global nature of the sanctions pressure on the Russian Federation.
Prohibiting Russian Uranium Imports Act
On May 13, 2024, President Joe Biden signed into law the “Prohibiting Russian Uranium Imports Act” (Public Law 118-62, 118th Congress), introduced by Congresswoman Cathy McMorris Rodgers and passed by the U.S. Congress. The law, which took effect on August 12, 2024, established a complete embargo on the importation into the United States of unirradiated low-enriched uranium produced in the Russian Federation or by Russian companies. Under the newly added Section 3112A(d) of the USEC Privatization Act (42 U.S.C. 2297h-10a), the importation of unirradiated low-enriched uranium produced in Russia, as well as uranium obtained from third countries through swaps, replacements, or other schemes aimed at circumventing the embargo, is prohibited from the effective date of the law (Sec. 2(a)(1)(A),(B)).
Sanctions Against Kaspersky Lab
On June 21, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), under Section 1(a)(i) of E.O 14024, imposed blocking sanctions against key executives of Kaspersky Lab for their critical role in supporting Russia’s technology industry, rendering them suitable targets for sanctions. The day before, on June 20, 2024, the U.S. Department of Commerce added JSC Kaspersky Lab, LLC Kaspersky Group, and the UK-based Kaspersky Labs Limited to the Entity List pursuant to E.O 13873 of May 15, 2019. This move effectively blocks Kaspersky Group companies from exporting their software to the United States.
OFAC Sanctions Against the Moscow Exchange, National Settlement Depository, and National Clearing Centre
The United States expanded sanctions against Russia under E.O 14024. The new blocking measures targeted key companies and organizations, including the Moscow Exchange, the National Settlement Depository, the National Clearing Centre, JSC Kazan Experimental Design Bureau SOYUZ, JSC RusGazDobycha, Sinara Transport Machines, Technopark Mordovia, Belgorod Shipyard, Dvizhenie Pervykh, Arctic LNG 1, Arctic LNG 3, ZAO Mekamineft, SOGAZ, Gazprom Invest, Goznak, JSC KONAR from Chelyabinsk, PJSC Seligdar, and JSC Uralredmet. These sanctions are aimed at undermining Russia’s economic and industrial infrastructure. Sanctions were also imposed on several individuals, including Russian gymnast Nikita Nagornyy, a board member of RusChemAlliance, Kirill Seleznev, and others accused of facilitating sanctions evasion.
Additionally, under E.O 14071, OFAC imposed a ban on the export of consulting and IT design services military applications, IT maintenance services, and cloud services to Russia for the following software categories: (i) enterprise management software; and (ii) design and manufacturing software.
U.S. Sanctions Related to the Two-Year Full-Scale Invasion of Ukraine and the Death of Navalny
The latest sanctions have significantly impacted both individuals and financial institutions. The list of sanctioned individuals includes 500 people, including key figures from the Yamalo-Nenets penal system. Among them are Vadim Kalinin, the head of IK-3 colony, where Alexei Navalny died, as well military officials such as high-ranking Federal Penitentiary Service officials Valery Boyarintsev and Igor Rakityn, whose actions were noted by President Putin following Navalny’s death. Sanctions also targeted Boris Gryzlov, Russia’s ambassador to Belarus. In the financial sector, sanctions affected 90 entities, including several key banks. Notably, Avangard Bank and seven regional banks were added to the Specially Designated Nationals (SDN) list. SPB Bank, which serves as the settlement depository for the St. Petersburg Exchange, was also subjected to blocking sanctions. Additionally, sanctions targeted several investment and venture capital funds, such as BSF Capital, Elbrus Capital, Orbita Capital Partners, as well as the Investment and Venture Fund of Tatarstan and Guard Kapital, which focuses on the IT sector in Russia. Of particular note are Elbrus Capital’s portfolio companies, including the job search service HeadHunter and the real estate listings platform Cian, which continues to resist delisting of its shares in the United States.
Executive Orders Related to Sanctions
Executive Order 14024 (April 15, 2021)
Blocking Property With Respect To Specified Harmful For- eign Activities of the Government of the Russian Federation
In response to the ongoing malign activities of the Russian Federation, which pose a threat to the national security, the foreign affairs, policy, and economy of the United States, President Joe Biden issued E.O 14024. This order establishes the blocking of all property and interests in property within the United States or under the control of U.S. persons, that belong to or are controlled by individuals involved in a range of harmful activities, including election interference, cyberattacks, international corruption, the undermining of democratic institutions, violations of the territorial integrity of states, as well as support for Russia’s defense and technology sectors (§1(a), E.O 14024). The order also extends to the blocking of assets of entities associated with the Russian government and individuals who provide support to such entities (§1(b), E.O 14024).
It is important to note that the new E.O 14114 has significantly expanded and clarified the application of E.O 14024, introducing new mechanisms for sanctioning. Specifically, provisions were introduced allowing the U.S. Department of the Treasury, in coordination with the Department of State, to impose sanctions on foreign financial institutions that conduct or facilitate significant transactions in support of individuals involved in supporting Russia’s military-industrial complex (§1(a)(ii), E.O 14114). These measures include a prohibition on opening correspondent accounts in the United States and blocking all assets of such institutions within U.S. jurisdiction (§1(b), E.O 14114). E.O 14114 also clarified prohibitions on providing goods, services, or funding to individuals whose assets are blocked and defined the term “foreign financial institution” broadly, covering a wide range of financial organizations (§1(f), E.O 14114). Moreover, E.O 14114 amended E.O 14068, tightening restrictions on the importation of products from the Russian Federation, including fish, seafood, alcoholic beverages, and diamonds (§3(a)(i), E.O 14114). The order also expanded the scope of products covered, adding categories of goods produced with Russian raw materials or harvested in Russian waters (§3(a)(i)(B), E.O 14114).
Executive Order 14039 (August 20, 2021)
Blocking Property With Respect to Certain Russian Energy Export Pipelines
E.O 14039 was issued by President Joe Biden as part of efforts to increase sanctions pressure on the Russian Federation in response to its malign foreign policy activities, including the construction and operation of energy export pipelines, which the U.S. administration considers a threat to Europe’s energy security. This order operates under the authority granted to the President by the Constitution and laws of the United States, including the International Emergency Economic Powers Act (IEEPA, 50 U.S.C. 1701 et seq.), the National Emergencies Act (NEA, 50 U.S.C. 1601 et seq.), the Protecting Europe’s Energy Security Act (PEESA), and Section 301 of the U.S. Code. The order targets the blocking of property and interests in property of certain foreign persons connected to Russian energy export pipelines. Specifically, under §1(a) E.O 14039, all assets of such persons within the United States, entering the United States, or under the control of U.S. persons are subject to blocking. These assets cannot be transferred, paid, exported, withdrawn, or otherwise dealt with.
Executive Order 14066 (March 8, 2022)
Prohibiting Certain Imports and New Investments With Re- spect to Continued Russian Federation Efforts To Undermine the Sovereignty and Territorial Integrity of Ukraine
On March 8, 2022, President Biden signed E.O 14066, which expanded the national emergency related to the full-scale invasion of Ukraine by the Russian Federation, as well as the ongoing, unprovoked, and unjustified aggression against Ukraine, including violations of international law and the United Nations Charter. This order aims to intensify sanctions pressure on Russia, particularly in the energy and manufacturing sector. The order prohibits the importation into the United States of certain products of Russian origin, including crude oil, petroleum products, petroleum distillates, liquefied natural gas, coal, and coal products (§1(a)(i)) E.O 14066. It also bans new investments in the Russian Federation’s energy sector by any “United States person,” regardless of their location (§1(a)(ii))E.O 14066. In this context, a “United States person” includes U.S. citizens, permanent residents, entities organized under U.S. law, and any person within the United States (§4(c)) E.O 14066.
The order further prohibits the approval, financing, facilitation, or guarantee by any “United States person” of any transaction by a foreign person, where such a transaction would be prohibited if performed by a “United States person” or within the United States (§1(a)(iii))E.O 14066. E.O 14066 also imposes strict prohibitions on any attempts to evade or violate the aforementioned restrictions (§2(a)-(b))E.O 14066.
Executive Order 14068 (March 11, 2022)
Prohibiting Certain Imports, Exports, and New Investment With Respect to Continued Russian Federation Aggression
On March 11, 2022, President Joe Biden dealt another significant blow to the Russian Federation’s economy and security sector by signing E.O 14068. This order reinforces previously enacted measures under E.O 14024 of April 15, 2021, and subsequent actions, including E.O 14039 of August 20, 2021, and E.O 14066 of March 8, 2022. Under §1(a)(i)E.O 14068, it prohibits the importation into the United States of key Russian-origin goods such as fish, seafood, alcoholic beverages, and non-industrial diamonds. However, this is not the end; at any time, the Secretary of the Treasury, in close coordination with the Secretary of State and the Secretary of Commerce, may expand this list.
In §1(a)(ii)E.O 14068, the order imposes a strict ban on the export and re-export of luxury items to Russia, regardless of the location of U.S. persons. This means that luxury goods advertising services are no longer accessible to elites under sanctions. The most decisive move is the restriction on new investments in any sector of the Russian economy as determined by the Secretary of the Treasury under §1(a)(iii)E.O 14068. Biden made it clear: Russia’s future development is under close scrutiny, and any dollar that could enter its economy will be blocked.
Additionally, pursuant to §1(a)(iv)E.O 14068, the provision of U.S. dollar banknotes to the Government of the Russian Federation or any person in Russia is now prohibited. The restrictions do not stop there: §1(a)(v)E.O 14068 introduces a ban on the approval, financing, facilitation, or guarantee by U.S. persons of any transactions that would be prohibited if conducted directly within the United States. This is not just a sanctions regime—it is a financial siege designed for long-term pressure.
Executive Order 14071 (April 6, 2022)
Prohibiting New Investment in and Certain Services to the Russian Federation in Response to Continued Russian Fed- eration Aggression
First and foremost, E.O 14071 imposes a total ban on any new investments in Russia by U.S. persons, regardless of their location. This is not merely a formality—it is a tangible blow to Russia’s investment attractiveness. From this point forward, any dollar invested in Russia by American citizens or companies becomes a risk that is unjustified even in the long term. The economic faucet has been shut off (§1(a)(i))E.O 14071.
Following this, the order has new bans on the export of certain services to Russia (§1(a)(ii)) E.O 14071. One of the key elements is the prohibition on participation in transactions conducted by foreign persons if they contradict the sanctions. Biden makes it clear: anyone who thinks they can circumvent sanctions through using third country countries or offshore entities will face consequences. The U.S. business community will no longer turn a blind eye to such maneuvers, and this message will be clearly heard by all (§1(a)(iii)) E.O 14071.
OFAC Sanctions List on Russia
Financial Sanctions on Russia
U.S. financial sanctions against the Russian Federation represent a powerful tool of economic pressure designed to isolate the Russian financial system from global financial markets and systems. These measures include asset freezes, prohibitions on conducting transactions in U.S. dollars, and restrictions on access to international financial markets. The foundation of these sanctions lies in E.O 14024 (April 2021), which expands the authority to sanction individuals and sectors supporting Russia’s aggressive policies; the Countering America’s Adversaries Through Sanctions Act (CAATSA, 2017), which restricts Russian entities’ access to American markets; and E.O 13662 (March 2014), which imposes measures against the financial sector and companies supporting destabilizing actions and other harmful activities. Key entities subject to financial sanctions include Sberbank, Russia’s largest bank, now barred from conducting U.S. dollar transactions; VTB Bank, the second-largest Russian bank, facing restrictions on international transactions; Gazprombank, vital to the energy sector, restricted in its foreign operations; Rosselkhozbank, facing asset freezes; Alfa-Bank, a private bank under restrictions on transactions with Western counterparts; and the Russian Direct Investment Fund (RDIF), deprived of opportunities for international investments. Additionally, entities such as Bank of Moscow, RTS, Moscow Exchange, Rosneft, Lukoil, Surgutneftegas, Tinkoff Bank, Credit Europe Bank, National Settlement Depository, Vnesheconombank (VEB), and United Shipbuilding Corporation are all under sanctions that have drastically altered their financial capabilities and strategies.
Sectoral Sanctions on Russia
Sectoral sanctions are targeted economic measures that strike at key sectors of the Russian economy, such as energy, defense, and high technology. These sanctions are aimed at limiting access to critical technologies and military equipment used, as well as curbing foreign investment in strategically important areas. E.O 13661 (March 2014) establishes sanctions against economic sectors supporting the destabilization of Ukraine; E.O 14024 (April 2021) expands sanctions across various economic areas linked to Russian aggression; and CAATSA (2017) imposes restrictions on investments and technology exports to strategic sectors. Entities affected by these sanctions include Rosneft, with restrictions on access to deepwater and Arctic drilling technologies; Gazprom, with a ban on the use of advanced technologies for shale gas; Lukoil, Surgutneftegas, Transneft, United Aircraft Corporation (UAC), Almaz-Antey, Kalashnikov Concern, Rostec, United Shipbuilding Corporation, Rosoboronexport, Uralvagonzavod, Tupolev, Sukhoi, Yakovlev, MiG, Severstal, and Metalloinvest. These measures severely hamper their operations and access to international markets and technologies.
Legal Assessment and Strategy Development for Contract and Operations Adaptation in the Energy Sector Considering Sanctions Imposed on Exports and Investments
Export and Import ban
Export restrictions and import restrictions are economic measures aimed at limiting trade and the exchange of critical technologies and resources. These sanctions include bans on the export of certain technologies and equipment to Russia, as well as the import of products manufactured in Russia, thereby hindering its economic development and production capabilities. The main legal instruments regulating this area include the Export Control Reform Act (2018), which controls the export of strategic technologies, and Bureau of Industry and Security (BIS) Rules. Examples of these sanctions include the ban on exporting semiconductors and microelectronics to Russia; the ban on exporting software and IT services; restrictions on the import of Russian precious metals, oil and gas, vodka, and caviar; and the ban on importing goods related to the defense industry and strategic resources. These measures place significant limitations on export and import operations, delivering a blow to Russian industry and the economy.
Sanctions on Individuals and Entities
Sanctions against individuals and organizations are measures aimed at freezing assets and restricting access for individuals and organizations involved in activities that threaten U.S. national security or violate international norms. These sanctions include asset freezes, travel bans to the U.S., and restrictions on financial transactions with American citizens and companies. The main legal instruments include the Global Magnitsky Act (2016), which imposes sanctions on individuals involved in human rights abuses and corruption, and E.O 14024 (April 2021), among others, which impose sanctions on individuals and organizations supporting Russia’s harmful actions. Sanctioned individuals include Vladimir Putin, Sergei Shoigu, Dmitry Medvedev, Alexey Miller, Igor Sechin, Anatoly Chubais, Yuri Chaika, Alexander Bastrykin, Yevgeny Prigozhin, the FSB, the GRU, the Central Bank of Russia, Wagner Group, United Shipbuilding Corporation, Roshydromet, Russian Academy of Sciences, Roscosmos, Space Research Institute, Russian Copper Company, and GAZ Group. These measures deeply impact personal and organizational assets, providing U.S. authorities with tools to exert pressure on key players in Russian politics and the economy. Sanctions measures are regularly contested, as evidenced by recent cases such as Streshinskiy et al. v. Smith et al., Zadornov v. Blinken et al., Astanin v. Yellen et al., Aliev et al. v. Blinken et al. (Bonum Capital), and Vassiliades et al. v. Blinken et al., demonstrating the relevance and fluidity of this issue.
Contact us for consultations on removal from the OFAC SDN List.
Penalties for Violation of Sanctions against Russia
Violating U.S. sanctions carries severe legal and financial consequences, reflecting the strict enforcement of these measures. The penalties are designed to prevent non-compliance and ensure adherence to established regulatory requirements. These penalties include both civil and criminal sanctions, as outlined below.
Civil penalties are financial sanctions imposed for violations of sanction regulations. The amount of civil penalties can be substantial and is determined based on the severity and nature of the violation. Under the International Emergency Economic Powers Act (IEEPA) and OFAC Regulations, civil penalties can reach up to $250,000 per violation or twice the amount of the transaction involved in the violation, whichever is greater. This broad authority allows the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) to impose significant fines for each separate violation. For example, companies such as Western Union and CitiBank have previously faced large civil penalties for failing to comply with sanction requirements.
Criminal penalties are applied for willful violations of sanctions and can include hefty fines as well as imprisonment. Under IEEPA and the Antiterrorism and Effective Death Penalty Act (AEDPA), individuals found guilty of intentionally violating sanctions can face up to 20 years in prison, in addition to significant fines. Criminal sanctions are imposed on individuals and organizations that knowingly attempt to evade or violate the sanctions regime. A notable example is the prosecution of Paul Manafort, who faced charges related to sanction violations as part of broader investigations into financial misconduct.
Enforcement actions can include both administrative and legal measures. These actions may involve asset forfeiture, suspension or revocation of business licenses, and inclusion on government blacklists. The U.S. government can impose restrictions on the ability to conduct transactions with U.S. citizens or entities, as well as access to the U.S. financial system. For instance, En+ Group faced significant restrictions and was compelled to divest certain assets as a result of enforcement actions.
Contact Russia Sanctions Lawyers
If you are facing challenges related to U.S. sanctions on Russia, whether due to potential violations, compliance concerns, or enforcement actions, it is crucial to seek expert legal advice. Our team of experienced Russia sanctions lawyers specializes in navigating the complex regulatory landscape imposed by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). We provide comprehensive legal guidance on issues ranging from financial sanctions, sectoral restrictions, and export controls to the defense against civil and criminal penalties. Whether you need assistance with understanding the implications of Executive Orders, or require strategic counsel on mitigating the risks of sanctions-related transactions, our attorneys are equipped to protect your interests and ensure full compliance with U.S. laws.
Contact us to safeguard your business and personal assets from the severe legal and financial consequences of sanctions violations.
