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Enforcement Edge
February 28, 2022

US Imposes Personal Sanctions on Russian President Vladimir Putin and Other Government Officials

Enforcement Edge: Shining Light on Government Enforcement

On February 25, the White House announced it would impose individual sanctions on Russian President Vladimir Putin and Russian Foreign Minister Sergey Lavrov. The move followed announcements from the European Union and the United Kingdom earlier in the day implementing similar personal sanctions. Acting pursuant to EO 14024, the Treasury Department’s Office of Foreign Assets Control added both President Putin and Mr. Lavrov to the Specially Designated Nationals (SDN) List. The designation of President Putin is notable because the US government rarely adds a head of state to the SDN list.

US persons, including US financial institutions, are prohibited generally from engaging in any transactions with SDNs and are required to block (i.e., freeze) any property or interests in property belonging to SDNs.

This is just the latest of sanctions imposed against Russia by the United States. Earlier last week, the United States issued significant sanctions and export control restrictions against Russia, including restrictions on major Russian financial institutions, state-owned enterprises, and several of Russia’s critical industries and sectors such as aviation, high tech and maritime. Meanwhile, the US government is still considering additional sanctions. In its decision Friday, OFAC noted several Russian Security Council members are already subject to the SDN List and indicated even more could be added in the future.

We will continue to monitor the sanctions and export control restrictions as they emerge.

© Arnold & Porter Kaye Scholer LLP 2022 All Rights Reserved. This blog post is intended to be a general summary of the law and does not constitute legal advice. You should consult with counsel to determine applicable legal requirements in a specific fact situation.