On April 6, the US Department of Treasury, Office of Foreign Assets Control (OFAC) announced the designation of 7 Russian oligarchs and 12 companies they own or control, 17 senior Russian government officials, and a state-owned Russian weapons trading company and its subsidiary, a Russian bank.

The new specially designated nationals (SDNs) also include entities that are owned 50% or more by a designated person under OFAC’s 50% Rule. If the designated persons have 50% or more ownership in a company, that company would also be blocked.

These new sanctions also have implications for non-US persons and entities. Reed Smith LLP said that while non-US persons generally are not subject to US sanctions, they may now face secondary sanctions under CAATSA for engaging in “significant” transactions with designated Russian parties or entities blocked as a result of OFAC’s 50% Rule.


Because OFAC’s designations now include a greater scope of Russian oligarchs, officials, and entities, non-US companies and financial institutions have to to carefully consider the risk of secondary sanctions when dealing with Russian parties in the future.

On March, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC), announced the imposition of sanctions against Russian entities and individuals. The New US Sanctions Targets included the designation of three entities and 13 individuals which are now included on OFAC’s SDN and Blocked Persons List.