On April 6, 2018, the Department of Treasury's Office of Foreign Assets Control ("OFAC") announced new Specially Designated National ("SDN") and Russian Sectoral Sanctions designations for a number of individuals and entities pursuant to its authority under Ukraine/Russia-related Executive Orders 13661 and 13662, the Syria Sanctions Regulations, and the Foreign Narcotics Kingpin Designation Act. In addition to these designations, OFAC issued General License 12 and General License 13, which authorize certain wind down and divestiture-related activities that would otherwise be prohibited as a result of the new designations.

A number of the designations announced on April 6 are directed at individuals who were previously identified by OFAC as Senior Political Figures or Oligarchs of the Russian Federation in its January 29, 2018 Report to Congress Pursuant to Section 241 of the Countering American's Adversaries Through Sanctions Act of 2017 Regarding Senior Foreign Political Figures and Oligarchs in the Russian Federation and Russian Parastatal Entities ("OFAC's Report to Congress"), as well as entities with which they are affiliated. While identification as a Russian Senior Political Figure or Oligarch did not immediately subject individuals to U.S. sanctions, suspicions that this listing could lead to sanctions designations in the future appears to be validated by OFAC's most recent designations. More than half of the individuals designated as SDNs on April 6 were previously identified in OFAC's Report to Congress, as follows:

^[1] Chairman of the Management Board of Gazprombank, which was previously designated as a Sectoral Sanctions Entity subject to Directive 1