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From Oligarch to SDN: New Designations Deepen Risks of Business with Russia

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:

Designations Associated with Russia/Ukraine Sanctions Program

April 6 Individual SDN Designations

Named Russian Oligarch or Senior Political Figure

Andrey Igorevich Akimov[1]

X

Vladimir Leonidovich Bogdanov

X

Oleg Vladimirovich Deripaska

X

Alexey Gennadyevich Dyumin

 

Mikhail Efimovich Fradkov

 

Sergei Fursenko

 

Oleg Govorun

X

Suleiman Abusaidovich Kerimov

X

Vladimir Alexandrovich Kolokoltsev

X

Konstantin Kosachev

 

Andrey Leonidovich Kostin

X

Alexey Borisovich Miller

X

Nikolai Platonovich Patrushev

X

Vladislav Matusovich Reznik

 

Igor Arkadyevich Rotenberg

 

Kirill Nikolaevich Shamalov

X

Evgeniy Mikhailovich Shkolov

X

Andrei Vladimirovich Skoch

X

Alexander Porfiryevich Torshin

 

Vladimir Vasilyevich Ustinov

X

Timur Samirovich Valiulin

 

Viktor Feliksovich Vekselberg

X

Alexander Alexandrovich Zharov

 

Viktor Vasiliyevich Zolotov

X

April 6 Entity Designations

OFAC Identified Affiliation

Agroholding Kuban 
Basic Element Limited 
B-Finance Ltd 
EN+ Group PLC 
GAZ Group 
Russian Machines 
JSC Eurosibenergo 
United Company Rusal PLC

Oleg Vladimirovich Deripaska

Gazprom Burenie, OOO 
NPV Engineering Open Joint Stock Company

Igor Arkadyevich Rotenberg

Ladoga Menedzhment, OOO

Kirill Nikolaevich Shamalov

Renova Group

Viktor Feliksovich Vekselberg

 


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

© 1998-2021 Wiggin and Dana LLPNational Law Review, Volume VIII, Number 124
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About this Author

Tahlia Townsend International trade lawyer Wiggin Dana
Partner

Co-chair of the International Trade Compliance Practice Group, Tahlia is trusted by Fortune 50 multinationals, leading universities, international law firms, emerging companies, and small businesses to provide prompt, practical, effective guidance and thought leadership on trade sanctions administered by the Office of Foreign Assets Controls (OFAC) and on U.S. export controls under the International Traffic in Arms Regulations (ITAR) and the Export Administration Regulations (EAR), and to develop tailored, risk-based programs for compliance with, obtain licenses for...

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