United States Pushes More Sanctions Against Russia and Prohibits Russian Gold Imports

The Department of Treasury issued additional sanctions against Russia, targeting almost 100 entities and individuals, and prohibited import of Russian gold.  The United States’ latest action reflected commitments recently reached among the G-7 alliance to prohibit gold imports and target Russia’s industrial base, military and intelligence units, and sanctions evaders.  To follow up on these commitments. FinCEN and the U.S. Department of Commerce announced their intent to prosecute aggressively any persons involved in sanctions evasion.

OFAC designated 70 entities, many of which are important to Russia’s defense industry, including Rostec, the key state-owned company in Russia’s defense sector, along with 29 individuals.  This latest action is designed to focus sanctions against Russia’s capabilities to develop and deploy weapons and technology used to support Russia’s ongoing war effort.

The U.S. State Department imposed its own sanctions against 45 entities and 29 individuals, including Russian military units and Russia’s Federal Security Service (“FSB”).  The State Department extended sanctions against 500 Russian military officers.

Also, OFAC prohibited the importation of Russian gold into the United States and FinCEN issued a joint alert with the Commerce Department’s Bureau of Industry and Security (“BIS”) warning parties involved in sanctions evasions.  Under the new gold import prohibition, the importation of gold of Russian origin is prohibited.  This new action excludes any Russian origin gold located outside of Russia before the effective date of the prohibition.

The U.S. action was joined by the United Kingdom, Canada and Japan.  OFAC warned U.S. persons to avoid any transactions involving Russian gold as a means to evade other applicable sanctions.

OFAC’s sanctions against Rostec are comprehensive.  Rostec is the foundation of Russia’s defense industry and covers Russia’s technology, aerospace and military-industrial expertise.  Rostec subsidiaries are involved in the automotive, defense, aviation and metals sectors.  In addition, Rostec facilitates international trade  in defense and related material, as well as dual-use items.  Rostec includes approximately 800 entities involved in a variety of sectors.  Rostec is also sanctions by Australia, Canada, the EU, New Zealand, Switzerland and the United Kingdom.

As part of this significant action, OFAC’s new prohibition extends to Rostec’s subsidiaries, including but not limited to, entities in the aerospace sector, defense technology sector, industrial export sectors, and management entities.

OFAC also designated three individuals and one entity (in Hong King) involved in evasion activities on behalf of a covert procurement network linked to Russia’s FSB.

As part of its effort to disrupt Russia’s control of the Donbas region, OFAC designated a number of government officials involved in the DNR and LNR regions.

To target Russia’s “enablers,” OFAC designated the Advanced Rersearch Foundation and Andrey Ivanovich Grigoryev as part of its crackdown against Russia’s technology and defense sectors.

FinCEN and BIS issued an alert of possible evasion activities urging financial institutions to remain vigilant for possible attempts to evade BIS export controls against Russia.

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