On June 2, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated and blocked numerous additional Russian and related entities that are “key networks” relied upon by President Vladimir Putin and other Russian elites “to attempt to hide and move money and anonymously make use of luxury assets around the globe.” Notable among the designated entities are: (i) Severgroup (an investment company with holdings in metallurgy, engineering, mining, banking, technology, media and finance); (ii) PJSC Severstal (a company operating in the steel and mining industry); (iii) Nord Gold PLC (a gold producing subsidiary of Severstal with operations in Russia, Africa, South America, and North America); and (iv) Limited Liability Company Algoritm (a Russian technology, media, and advertising company).

Also added to the SDN List were additional Russian government ministers as well as the presidents of United Aircraft Corporation and Severgroup. The OFAC designation also include several yachts, aircraft and a helicopter – and related operating entities – with ownership ties or interests to President Putin or the government of Russia.

Detailed identifying information on these entities can be found here. All property and interests in property of these newly designated SDN List entities that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. In addition, any entities that are owned, directly or indirectly, 50% or more by one or more blocked persons are also blocked. All transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or otherwise blocked persons are prohibited unless authorized by a general or specific license issued by OFAC, or exempt.

Russia-Related General Licenses

OFAC has revised General License (GL) 25B authorizing certain transactions related to telecommunications and Internet-based communications to specifically exclude LLC Algoritm. The following new Russia-related GLs have been issued:

  • GL 36 – authorizes, until August 31, 2022, all transactions ordinarily incident and necessary to the wind-down of transactions involving JSC Severstal.
  • GL 37 – authorizes, until July 1, 2022, all transactions ordinarily incident and necessary to the wind-down of transactions involving Nord Gold PLC.
  • GL 38 – authorizes all transactions ordinarily incident and necessary for the processing of pension payments to U.S. persons via certain OFAC-blocked financial institutions.
Photo of Scott E. Diamond** Scott E. Diamond**

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor…

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor compliance, corporate anti-boycott and antibribery compliance, national security investigations, and foreign direct investment in the United States.

**Not licensed to practice law.

Photo of Samir D. Varma Samir D. Varma

Samir advises multinational corporations on export controls, economic sanctions and customs, and counsels individuals and corporations on the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws. He represents clients in enforcement actions before U.S. regulatory agencies and conducts corporate internal investigations.

Photo of Francesca M.S. Guerrero Francesca M.S. Guerrero

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some…

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some of their most challenging international transactions, involving dealings in high-risk jurisdictions or with high-risk counterparties. Francesca also counsels companies through all phases of internal investigations of potential trade and antibribery violations and represents companies across industries before related government agencies.