Background

The Biden administration announced last week trade sanctions on nearly 400 entities and individuals for enabling Russia’s prosecution of its war against Ukraine.

The Treasury Department’s Office of Foreign Assets Control has sanctioned 275 individuals and entities involved in supplying Russia with advanced technology and equipment. OFAC states that these sanctions target 150+ domestic Russian importers and producers of key inputs and other materiel for Russiaʼs military-industrial base as well as more than 120 individuals and entities involved in sanctions evasion networks across 17 jurisdictions, including India, China, Switzerland, Thailand, and Türkiye.

Under this action all property and interests in property of those sanctioned that are in the U.S. or in the possession or control of U.S. persons are blocked and must be reported to OFAC. Any entities that are owned, directly or indirectly, 50 percent or more by one or more blocked persons are also blocked. All transactions by U.S. persons or within (or transiting) the U.S. that involve any property or interests in property of designated or blocked persons are prohibited unless authorized by a general or specific license issued by OFAC, or exempt. Further, non-U.S. persons are prohibited from (1) causing or conspiring to cause U.S. persons to wittingly or unwittingly violate U.S. sanctions and (2) engaging in conduct that evades U.S. sanctions.

Further, the State Department’s Directorate of Defense Trade Controls has imposed sanctions on more than 120 individuals and entities to target sanctions evasion and circumvention in multiple third countries, including China, India, Malaysia, Thailand, Türkiye, and the United Arab Emirates. Those affected include China-based companies exporting dual-use goods that fill critical gaps in Russiaʼs military-industrial base as well as companies supporting Russiaʼs future energy production and exports.

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