Overview
On March 2, 2021, the US Departments of Treasury, State, and Commerce announced the coordinated imposition of sanctions and other restrictive measures on Russia and Russian officials and entities for the “poisoning and subsequent imprisonment of Russian opposition figure Aleksey Navalny.” The Department of the Treasury added seven Russian officials and entities to the Specially Designated Nationals and Blocked Persons List (the SDN List) pursuant to Executive Order (EO) 13661 and EO 13382, thereby blocking their property or interests in property that come within the possession of US persons or the jurisdiction of the United States. US persons are now prohibited from engaging in transactions with these SDNs. The State Department designated seven entities under its own authority, including four that were already on the SDN List. Treasury further expanded the sanctions applied to Russia in 2018 after the poisoning of Sergei Skripal in the UK, and named six entities as operating for the Russian defense sector, triggering sanctions. The Commerce Department announced the addition of fourteen entities to the Entity List, which triggers a licensing requirement for exports, re-exports, and in-country transfers to those entities of all items subject to the US Export Administration Regulations (EAR).
OFAC Designations
The US Treasury Department’s Office of Foreign Assets Control (OFAC) added to the SDN List the following seven Russian government officials pursuant to EO 13661 (March 17, 2014), “Blocking Property of Additional Persons Contributing to the Situation in Ukraine,” for “serving as officials of the Russian government.”
- Federal Security Service (FSB) Director Aleksandr Bortnikov (Bortnikov)
- Chief of the Presidential Policy Directorate Andrei Yarin (Yarin)
- First Deputy Chief of Staff of the Presidential Executive Office Sergei Kiriyenko (Kiriyenko)
- Deputy Minister of Defense Aleksey Krivoruchko (Krivoruchko)
- Deputy Minister of Defense Pavel Popov (Popov)
- Federal Penitentiary Service (FSIN) director Alexander Kalashnikov (Kalashnikov)
- Prosecutor General Igor Krasnov (Krasnov)
- Authorizes transactions and activities with the FSB that are “necessary and ordinarily incident to requesting, receiving, utilizing, paying for, or dealing in certain licenses and authorizations for the importation, distribution, or use of certain information technology products” in Russia (FAQ 501);
- Only authorizes certain transactions and activities with the FSB “acting in its administrative and law enforcement capacities” (FAQ 502); and
- Does not authorize the exportation of hardware or software directly to the FSB, or where the FSB is the end user of such hardware and software (FAQ 503).
- State Scientific Research Institute of Organic Chemistry and Technology (GosNIIOKhT)
- 33rd Scientific Research and Testing Institute (33rd TsNIII)
- 27th Scientific Center (27th NTS)
- Federal Security Service (FSB)
- Main Intelligence Directorate (GRU)
- GRU officer Alexander Yevgeniyevich Mishkin (Mishkin)
- GRU officer Anatoliy Vladimirovich Chepiga (Chepiga)
- Certain Commerce Department dual use export license exceptions remain available for exports and reexports to Russia: Temporary Imports, Exports, and Reexports (TMP); Governments, International Organizations, and International Inspections under the Chemical Weapons Convention (GOV); Baggage (BAG); Aircraft and Vessels (AVS); or Encryption Commodities and Software (ENC).
- Dual use items needed to ensure the safe operation of commercial passenger aviation will not be subject to sanctions restrictions;
- Exports to wholly-owned subsidiaries of US and other foreign companies operating in Russia will not be affected;
- The Commerce Department will continue to process applications for “deemed exports” to Russian nationals working in the United States on a case-by-case basis; and
- Exports in support of US-Russian government space cooperation remain unaffected.
- Commerce Department license exceptions Service and Replacement of Parts and Equipment (RPL), Technology and Software Unrestricted (TSU), and Additional Permissive Reexports (APR) are no longer available;
- Applications for the export, reexport, or in-country transfer of “national security” (NS) controlled items to commercial end-users in Russia for civil end-uses will now be reviewed with a presumption of denial; and
- Applications for the export of US Munitions List items and Commerce Control List NS-controlled items in support of commercial space flight activities in Russia will be reviewed under a presumption of denial after a six month transition period.
- 27th Scientific Center
- 33rd Scientific Research and Testing Institute (aka 33rd TsNIII)
- 48th Central Scientific Research Institute Kirov (aka 48th Central Research Institute Kirov; aka 48th TsNII)
- 48th Central Scientific Research Institute Sergiev Posad (also known as [aka] 48th TsNII Sergiev Posad; aka 48th Central Research Institute, Sergiev Posad)
- 48th Central Scientific Research Institute Yekaterinburg (aka 48th TsNII Yekaterinburg)
- State Scientific Research Institute of Organic Chemistry and Technology (aka GoSNIIOKhT)
- The 27th Scientific Center of the Russian Ministry of Defense (a.k.a., 27th NTs) (Russia)
- Chimmed Group (Russia)
- Chimconnect GmbH (Germany)
- Chimconnect AG (Switzerland)
- Pharmkontract GmbH (Germany)
- Femteco (Russia)
- Interlab (Russia)
- LabInvest (Russia)
- OOO Analit Products (Russia)
- OOO Intertech Instruments (Russia)
- Pharmcontract GC (Russia)
- Rau Farm (Russia)
- Regionsnab (Russia)
- Riol-Chemie (Germany)