Russia OFAC Sanctions
Following Russia’s invasion of Ukraine, OFAC expanded Russia-related sanctions to be among the most extensive ever imposed. Our lawyers advise on Russia sanctions compliance, secondary sanctions risk assessment, SDN list matters, and asset unblocking for clients affected by Russia-related designations.
Quick Answer: Russia Sanctions 2026
U.S. sanctions on Russia represent one of the most expansive sanctions regimes ever imposed, covering financial services, energy, defense, technology, IT services, and luxury goods. Since February 2022, OFAC has designated over 1,000 Russian individuals and entities. In January 2025, OFAC added sweeping petroleum services bans and energy sector determinations that took full effect in February 2025. The program is governed by Executive Orders 14024, 14068, and 14071.
The sanctions Russia framework represents a historic escalation of U.S. economic pressure. Following Russia’s full-scale invasion of Ukraine in February 2022, the United States — acting through the Office of Foreign Assets Control (OFAC) — expanded what were already substantial targeted measures into one of the most comprehensive sanctions regimes in U.S. history. Understanding the current scope of us sanctions on russia is essential for any business, financial institution, or individual operating in global markets.
Russia Sanctions Timeline: From 2014 to 2026
U.S. sanctions on Russia have been built layer by layer since the 2014 annexation of Crimea, with massive expansion beginning in 2022.
| Year | Order / Law | Key Restriction |
|---|---|---|
| 2014 | Executive Order 13660 | Blocking sanctions on persons threatening Ukraine’s sovereignty; asset freezes and travel bans |
| 2014 | Executive Order 13661 | Expanded blocking to officials of the Russian government and arms/materiel exporters |
| 2014 | Executive Order 13662 | Sectoral sanctions (Directives 1–4): restrictions on debt/equity transactions with designated Russian entities in financial, energy, defense sectors |
| 2017 | CAATSA (Countering America’s Adversaries Through Sanctions Act) | Codified existing Russia sanctions; established congressional review for sanctions relief; added new secondary sanctions authorities |
| 2021 | Executive Order 14024 | Primary authority for post-2022 expansion: authorizes sanctions on persons operating in key Russian sectors; basis for most 2022–2026 designations |
| 2022 (Feb) | EO 14024 Determinations | Financial services, technology, defense sectors fully sanctioned; Sberbank, VTB, Gazprombank, and other major banks blocked |
| 2022 (Mar) | Executive Order 14068 | Prohibited export of luxury goods to Russia; import ban on Russian seafood, spirits, and non-industrial diamonds |
| 2022 (Jun) | Executive Order 14071 | New investment in Russia prohibited; ban on provision of IT services, architectural, engineering, legal, and accounting services to Russia by U.S. persons |
| 2022 (Sep) | EO 14071 Expansion | Accounting, trust, corporate formation, and management consulting services to Russia added to services ban |
| 2023 | G7 Price Cap Enforcement | $60/barrel crude oil price cap enforced; violations trigger SDN designations; tanker fleet sanctioned |
| 2025 (Jan 10) | EO 14071 Petroleum Services Ban | Comprehensive ban on petroleum services to any Russian person; effective February 27, 2025; ~100 entity re-designations under EO 13662 |
| 2025 (Jan 15) | EO 14024 Military-Industrial Base | 150+ additional designations targeting Russia’s military-industrial suppliers, including PRC-based companies facilitating evasion |
| 2026 (Jan 21) | Federal Register — EO 13662 Directive 4 | Updated secondary risk guidance for financial institutions; renewed focus on Directive 4 compliance |
| 2026 (Mar 5) | GL Amendment | Amended General License for two petroleum processors; wind-down period adjusted |
Current Russia OFAC Sanctions: What Is Prohibited in 2026
The scope of russia sanctions 2026 covers virtually every major sector of the Russian economy. U.S. persons — including citizens, residents, and U.S.-organized entities worldwide — face strict prohibitions across multiple categories.
| Sector | Restriction | Key Authority |
|---|---|---|
| Financial Services | Major Russian banks fully blocked (Sberbank, VTB, Gazprombank, Alfa-Bank, Otkritie, Sovcombank, Bank Rossiya); correspondent account restrictions | EO 14024; SSI Directives 1–4 |
| Energy — Oil & Gas | New investment in Russia’s energy sector prohibited; petroleum services ban (effective Feb 27, 2025); $60/barrel crude oil price cap | EO 14071; EO 14024 energy determination |
| Defense & Military | All transactions with Russia’s defense and military sector prohibited; exports of defense articles, arms, materiel banned | EO 13661; EO 14024 defense determination |
| Technology & Dual-Use | BIS/OFAC joint enforcement; extensive export controls on semiconductors, electronics, software; ban on IT services to Russia | EO 14071; BIS Entity List |
| IT & Cloud Services | U.S. persons prohibited from providing IT services, cloud services, and software to Russian persons | EO 14071 (Jun 2022) |
| Professional Services | Accounting, legal, management consulting, trust/corporate formation, engineering, architecture services to Russia prohibited for U.S. persons | EO 14071 (Sep 2022) |
| Luxury Goods | Export of luxury goods (watches, jewelry, vehicles >$50K, fashion apparel, spirits) to Russia or Russian persons prohibited | EO 14068 |
| Debt & Equity | New debt (>14 days maturity) and new equity in Russian entities restricted; secondary market restrictions via Directive 4 | EO 13662 Directives 1–4 |
| Russian-Origin Imports | Ban on imports of Russian oil, gas, coal, seafood, spirits, diamonds, and other products into the United States | EO 14066; EO 14068 |
Key General Licenses for Russia Sanctions
OFAC has issued numerous General Licenses (GLs) to authorize specific activities that would otherwise be prohibited under us sanctions on russia. Key GLs include:
- GL 4 (as amended): Authorizes transactions related to the official business of international organizations and certain U.S. government activities
- GL 8E (as amended): Authorizes energy-related transactions — used heavily during the 2022–2024 wind-down period; now significantly narrowed by the 2025 petroleum services ban
- GL 25: Authorizes certain transactions relating to the Russian Central Bank’s assets held at the Federal Reserve (sovereign assets subject to G7 immobilization)
- GL March 2026 Amendment: Amended authorization for two specific petroleum processors — reflects ongoing fine-tuning of energy sector restrictions
- Humanitarian GLs: Authorize food, medicine, medical devices, and NGO-related activities
For businesses that need to continue legitimate activities in Russia — such as winding down existing contracts, managing legacy investments, or providing authorized humanitarian services — a specific OFAC license may be required. Our attorneys assist clients through the licensing process.
Russia SDN List: Scale and Scope
Since February 2022, OFAC has designated over 1,000 Russian individuals and entities on the Specially Designated Nationals (SDN) list. Designated parties include:
- Oligarchs and business elites: Individuals with close ties to the Kremlin, including major shareholders in Russian energy, banking, and media companies
- Government officials: President Putin, senior ministers, Duma members, regional governors who supported the invasion
- Defense entities: Major Russian defense manufacturers, weapons exporters, and procurement networks — including PRC-based shell companies used for sanctions evasion
- Financial institutions: Over 90% of Russia’s banking sector assets now under blocking sanctions or sectoral restrictions
- Shadow fleet tankers: Vessels used to transport Russian oil above the G7 price cap, designated for violating the price cap regime
Secondary Sanctions Risk
One of the most significant developments in russia sanctions 2026 is the expanded use of secondary sanctions authority. Under EO 14024 and CAATSA, OFAC can designate non-U.S. persons — including foreign banks and companies — for conducting significant transactions with already-designated Russian parties. This means that even foreign companies with no U.S. nexus face the risk of SDN designation if they support Russia’s war economy.
In January 2026, updated EO 13662 Directive 4 guidance reinforced secondary sanctions risk for foreign financial institutions processing transactions on behalf of sanctioned Russian entities. Chinese, Indian, Turkish, and UAE-based companies have faced increasing secondary sanctions pressure for facilitating Russian trade.
Compliance for Businesses Operating in or with Russia
Given the breadth of us sanctions on russia, virtually every multinational company must have robust sanctions compliance programs. Our OFAC attorneys advise on:
- Transaction screening against the SDN and Sectoral Sanctions Identifications (SSI) lists
- Applying the OFAC 50% Rule to identify blocked entities not explicitly named on the SDN list
- Structuring wind-down transactions within applicable GL authorizations
- Responding to OFAC investigations and enforcement actions
- Managing blocked Russian assets and petitioning for licenses to unblock or transfer funds
Need Help Navigating Russia Sanctions?
Our OFAC sanctions lawyers have handled 500+ cases involving Russia sanctions. From SDN compliance to blocked assets and license applications, we provide expert guidance on the world’s most complex sanctions regime. Free initial consultation.
Frequently Asked Questions
What are Russia OFAC sanctions?
Russia OFAC sanctions are a set of U.S. sanctions programs targeting Russian government officials, oligarchs, financial institutions, and industries in response to Russian aggression against Ukraine and other malign activities. Since 2022, they have expanded dramatically and now cover the financial, energy, defense, technology, and services sectors.
Do Russia sanctions apply to non-U.S. companies?
Yes — through secondary sanctions. Non-U.S. companies that engage in significant transactions with sanctioned Russian entities or in prohibited sectors risk being added to OFAC’s SDN list, losing access to U.S. markets and the global dollar system. Many non-U.S. banks and companies have restricted Russia-related business due to this risk.
What is the Russia oil price cap?
The G7 oil price cap ($60/barrel for seaborne Russian crude) is enforced partly through OFAC sanctions. Non-U.S. companies that provide shipping, insurance, or financial services for Russian oil above the price cap are at risk of U.S. sanctions. Our lawyers assess price cap compliance for shipping and trading companies.
Can I provide IT services to Russia?
EO 14071 (June 2022) prohibits U.S. persons from providing IT services to Russia, including cloud computing, software as a service (SaaS), and technical support. This applies to U.S. companies and their foreign subsidiaries. OFAC has issued general licences for certain wind-down transactions and software security updates.
My assets were frozen due to Russia-related sanctions — what can I do?
If you are on the SDN list or if your assets were blocked due to Russia-related sanctions, there are legal options: SDN list removal petition, specific OFAC licence application, and in some cases, challenge of the designation. Our lawyers have experience representing clients in Russia-related OFAC proceedings. Contact us for a confidential assessment.
Are there any wind-down licences for Russia-related business?
OFAC regularly issues general licences to allow wind-down of existing Russia-related business before full prohibitions take effect. These licences have specific deadlines and transaction limits. Our lawyers monitor all Russia-related OFAC licences and advise clients on compliant wind-down procedures. Contact: [email protected] | +357 96 447475