On March 15, 2018, the U.S. Treasury Department announced the addition of five Russian entities and 19 individuals to the Specially Designated Nationals (SDN) List in connection with Russian interference in U.S. elections, destructive cyber-attacks against the U.S., and intrusions targeting critical U.S. infrastructure. These entities and individuals were designated by the Treasury Department’s Office of Foreign Asset Control (OFAC) under Executive Order (E.O.) 13694, titled “Blocking the Property of Certain Persons Engaging in Significant Malicious Cyber-Enabled Activities,” and the Countering America’s Adversaries Through Sanctions Act (CAATSA). CAATSA is the measure Congress passed last year to sanction Russia’s defense and intelligence sectors.
Entities and individuals designated under E.O. 13694 include Internet Research Agency LLC (IRA), which took actions to interfere with or undermine U.S. election processes and institutions, numerous individuals associated with IRA, Russian oligarch Yevgeniy Prigozhin, and entities linked to Prigozhin. Entities and individuals designated under CAATSA include the Russian Federal Security Service (FSB) and Main Intelligence Directorate (GRU), which engage in activities that significantly undermine cybersecurity on behalf of the Russian government, and several FSB and GRU officials.1
As with all SDNs: (i) any property and interests in property of designated persons that is subject to U.S. jurisdiction is blocked; (ii) designated persons are barred from traveling to the U.S.; and (iii) U.S. persons are generally prohibited from engaging in transactions with designated persons.
If you have any questions or concerns about U.S. sanctions, please contact one of the attorneys listed below.
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1 See the U.S. Treasury Department’s press release titled “Treasury Sanctions Russian Cyber Actors for Interference with the 2016 U.S. Elections and Malicious Cyber-Attacks” for a complete list of entities and individuals designated under E.O. 13694 and CAATSA.
