Overview of the Western Response to the 2022 Russian Invasion of Ukraine

March 11, 2022

In response to the Russian invasion of Ukraine, the United States has sought to act in lockstep with the European Union, the United Kingdom, and any other partners it can rally to impose unprecedented economic costs on Russia. The stated goal of the Biden administration is to eliminate the ability to do business across most of Russia’s economic sectors. The U.S. has so far sought to isolate Russian President Vladimir Putin from the international community through strict sanctions on financial institutions, targeting government officials and Russian elites with visa restrictions and property blocking sanctions, and imposing significant export controls. These steps are in addition to efforts targeting Russia’s ability to fundraise off its sovereign debt and Russian banks’ ability to communicate with other financial institutions. 

President Putin has shown no signs of seeking an “off-ramp.” He is not interested in a diplomatic resolution at this time and has not sought to deescalate tensions. Furthermore, perceptions of the savagery of the Russian invasion have created an environment where it is unlikely that Ukrainian President Zelenskyy will accept anything other than the complete removal of Russia from Ukraine, as it does not wish to be an “in-between area” ever again. The administration has recognized these realities and has closed the door to diplomacy with Russia for the moment, noting there needs to be clear de-escalation by Russia for diplomatic engagement to begin again. The White House appears to increasingly view its role as waging economic warfare against Russia, despite the implications to U.S. and international businesses stemming from its cost-imposing measures. The administration is taking steps to minimize the impact on Americans’ wallets, however. With Russia not seeking de-escalation, and Ukraine unwilling to make more concessions on its sovereignty, it is likely the U.S. and its partners will continue adding to cost-imposing measures, like additional sanctions and trade restrictions, as the conflict progresses. Acknowledging that the situation is changing rapidly, this memo details: 

1. Current measures imposed to counter Russian aggression and inflict economic pain on the Russian economy 

  • Property Blocking Sanctions & Visa Restrictions
  • Export Controls & Trade Restrictions
  • SWIFT
  • Central Bank of Russia
  • Sovereign Debt
  • Oil and Gas Import Restrictions
  • Airspace Restrictions
  • Actions by State and Local Governments

2. Implications and trends going forward 

  • Impact on the Russian Economy
  • Additional Targets for Sanctions
  • International Pressure
  • Cybersecurity
  • Congressional Action

3. List of entities and individuals recently sanctioned by the U.S.

Current Measures Imposed

Property Blocking Sanctions and Visa Restrictions 

The U.S has imposed a range of actions on Russian entities and individuals, preventing accessing to assets in the West and travel to the United States. The U.S. government has emphasized extending these sanctions to include family members, noting that Russian elites have historically moved assets to family members to evade Western sanctions. The Biden administration has imposed property blocking sanctions on several Russian financial institutions, preventing their ability to operate or conduct transactions in the United States or with U.S. entities, released several tranches of sanctions aimed at elites in Putin’s vicinity, announced impending visa restrictions on over a dozen Russian oligarchs and their families, and has rolled out a series of sanctions targeting Russian media organizations and employees pushing disinformation. The Biden administration has repeatedly said that Russian elites are “on notice” that they could be added to U.S. sanctions lists at any time in the days and weeks ahead. We expect that additional banks and individuals could be added to these lists as the invasion progresses.

Though there is not complete overlap between the U.S., EU, and UK sanctions lists, the three are making efforts to support or endorse the actions of the others, and the United States and the EU have committed to forming a task force to ensure that the sanctions are coordinated and effective, and to prevent Russian elites from evading sanctions in the West. The U.S. version of this task force, called Task Force KleptoCapture, will marshal the resources of various federal agencies, including the IRS, FBI, Federal Marshals, the Secret Service, and DHS, to enforce the sweeping economic measures that the United States has imposed against Russia, and will be overseen by Deputy Attorney General Lisa Monaco.

Export Controls and Trade Restrictions

The U.S. has imposed export controls on Russia, including Russia-wide denial of exports of sensitive technology, primarily targeting the Russian defense, aviation, and maritime sectors to cut off Russia’s access to cutting-edge technology. In addition to sweeping restrictions on the Russian-defense sector, the U.S. government has imposed Russia-wide restrictions on sensitive U.S. technologies produced in foreign countries using U.S.-origin software, technology, or equipment. This includes Russia-wide restrictions on semiconductors, telecommunications, encryption security, lasers, sensors, navigation, avionics, and maritime technologies, and on technologies used for oil and gas development. These export controls, particularly those impacting semiconductors, are already having disruptive impacts on Russia’s manufacturing capabilities. The Department of Commerce has also added 91 new parties across 10 countries to the Entity List, restricting exports to those companies for their involvement in or support for Russian military and security endeavors.

President Biden has stated the goal of these export controls is to prevent Russia from building a 21st century economy, noting that these export controls will cut half of all of Russia’s high-tech imports, when combined with other export control regimes other partners are imposing. Some members of Congress have called for action on trade to go further, with a bipartisan and bicameral group introducing legislation to alter Russia’s trade status to make it easier to impose tariffs and restrict imports.

To further isolate Russia from the global community, and in part driven by Russia’s continued loosening of its rules of engagement as it proceeds with its invasion of Ukraine, the White House announced on 3/11, in conjunction with the G7 and the EU, that they would be stripping Russia of its most favored nation/ permanent normal trade relations (PNTR) status. Revoking this status means the U.S. is no longer obligated to grant Russia trade advantages, like reduced tariffs, on imported goods. This marks significant action that could precipitate removing Russia from the World Trade Organization, as all members of the WTO are obligated to grant most favored nation status to other members. Revoking PNTR status for Russia requires legislative approval by Congress, which could come as soon as next week given bipartisan and bicameral support. President Biden, in conjunction with other G7 leaders, also announced a new effort to deny borrowing privileges for Russia at multilateral financial organizations, including the IMF and World Bank. 

In addition, President Biden announced a ban on imports of several signature sectors from the Russian economy, including seafood, spirits/vodka, and non-industrial diamonds, and would ban the export of luxury goods from the U.S. to Russia. Building from the prohibition on new investments in the Russian energy sector, the White House is also releasing an EO establishing legal authority for future investment restrictions in any sector of the Russian economy.

SWIFT

After intense deliberation by U.S. and EU officials, the EU, which holds jurisdiction over the Society for Worldwide Interbank Financial Telecommunications (SWIFT), the international financial messaging system that allows banks across the world to interact with each other, prohibited seven Russian financial institutions from accessing the financial messaging system – Bank Otkritie, Novikombank, Promsvyazbank, Rossiya Bank, Sovcombank, VNESHECONOMBANK (VEB), and VTB BANK. This decision, among other plans, could have severe effects on the Russian economy, Russia’s creditors, and the ability for Russia to import and export goods.

SWIFT is a cross-border interbank payments financial system that banks and other financial institutions use to send information accurately, expeditiously, and securely and to make financial transfers. SWIFT is member-owned cooperative system that works by assigning each member institution a unique ID code that identifies the bank’s name, country of origin, city, and branch. If Russia were to be cut off from the SWIFT system, they would not only lose access to the message codes used for transmitting information and to make financial transactions, they would lose access to over 11,000 institutions, the ability to send roughly 43 million messages per day related to business and compliance intelligence, the ability to coordinate with 22 other countries, and access to the most dominant messaging services [although there are other services like Ripple and Clearing House Interbank Payments System (CHIPS)]. 

Cutting Russia off from SWIFT sends a strong message to Putin and the Russian government. The United States previously threatened to cut Russia off from SWIFT over the 2014 invasion of Crimea, which prompted the development by the Central Bank of Russia of the System for Transfer of Financial Messages (SPFS). There were previous efforts to link SPFS with other payment systems in China, India, Iran, and the Eurasian Economic Union. Currently, 23 banks in Armenia, Belarus, Germany, Kazakhstan, Kyrgyzstan, and Switzerland can connect to the SPFS system in Russia, but in general, the removal from the SWIFT system largely cuts several Russian banks off from the majority of international financial transactions. There are concerns of spillover effects from removing access to SWIFT, particularly around missed payments and overdraft fees across the international financial system, as well as concerns about the supply of dollars in markets. The EU has so far been careful to craft SWIFT restrictions in a way that minimizes strain on energy payments. The United States has emphasized that additional action on SWIFT could occur in the future.

Central Bank of Russia 

The Biden administration announced further sanctions against the Central Bank of Russia that prohibit Americans from doing any business with the Russian Central Bank and freezes the bank’s assets, including foreign currency reserves, within the U.S. Additionally, the measure targets the National Wealth Fund of the Russian Federation and the Ministry of Finance the Russian Federation. 

These restrictions directly impact over $630 billion in reserves and block attempts for Russia to support the ruble, as sanctions from the West continue to target Russia’s economy. These measures took effect immediately to prevent the Russian Central Bank from being able to move assets. This, coupled with the other restrictive measures, adds on to the goal to prevent Russia from deploying international reserves, which could undermine Western sanctions. 

Sovereign Debt 

The Biden administration has imposed sanctions to prohibit certain dealings involving Russian sovereign debt.  These directives prevent Russia from raising funds or trading on U.S. primary or secondary markets and prohibit U.S. financial institutions from participating in the primary market for ruble or non-ruble denominated bonds issued by the Russian Central Bank, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation. 

This also prevents the lending of ruble or non-ruble denominated funds and participation in the secondary market for ruble or non-ruble denominated bonds. Major financial institutions have begun reviewing and exploring how these new sanctions will impact international investors that hold these Russian sovereign bonds. However, these sanctions on sovereign debt are likely to have the most limited economic effects, as the ownership of sovereign debt is limited in scope. 

Airspace Restrictions

In addition to economic efforts, President Biden announced he would be closing U.S. airspace to Russian-owned and Russian-operated aircraft, including private planes owned by Russian elites. This action came not long after similar announcements by the UK and EU. Russian aircraft can only enter U.S. airspace if the flight is pre-approved by the FAA and DOT, or by the Department of State for diplomatic travel.

Oil and Gas Import Restrictions

The Biden administration announced on 3/8 that it is banning the import of Russian energy, including crude oil; petroleum; petroleum fuels, oils, and products of their distillation; liquefied natural gas; coal; and coal products. Significantly, this is the first major cost-imposing measure that the United States is taking unilaterally, with no similar action expected by the EU at this time. The UK has also announced they will begin a process to phase out imports of Russian oil, forming a task force to find alternative supplies with a goal of phasing out imports of Russian oil by the end of 2022. In announcing this new policy, President Biden highlighted that the United States, as a net energy exporter, is in a unique position to immediately cut off Russian energy imports. The Executive Order also prevents any new U.S. investment in Russia’s energy sector and will prohibit Americans from financing or enabling foreign companies that are investing in Russian energy production. Notably, the administration declined to impose sanctions in this sector, allowing foreign countries to continue the importation of Russian energy products without running afoul of U.S. sanctions.

Biden’s actions came as calls from Congress to cut off Russian oil imports became too loud to ignore. There was significant bipartisan consensus across both leadership and rank-and-file within both chambers of Congress for the U.S. government to target Russian energy imports. Initially, the Biden administration was hesitant to target the energy sector due to concerns of spillover effects for domestic energy prices, and sanctions were specifically designed to allow energy payments to continue. The White House has described this move as designed to show Putin the U.S. is prepared to go after a large revenue generator for Russia while ensuring markets have the time to adjust. 

Actions by State and Local Governments

As noted, over the course of the last two weeks, the U.S. Federal government and Western allies have taken actions to sanction Russia for the invasion of Ukraine. This action has been met with some parity from U.S. state governments, most notably from lawmakers in a dozen or so states moving for state agencies to divest from Russian businesses. California, Connecticut, Georgia, Illinois, Pennsylvania, New Jersey, New York, North Carolina, South Carolina, Virginia, and West Virginia have either proposed or implemented measures to cut off or review financial ties, including state pension programs. California is home to the largest U.S. pension fund, the California Public Employees’ Retirement System (CalPERS), which has ceased all Russian-related transactions. Retirement systems and state treasurers are feeling increased political pressure to divest from Russia. 

Additionally, there are calls for Russian-made goods, most notably Russian-made vodka, to be removed from shelves. Another notable state action includes the Executive Order signed by New Jersey Governor Phil Murphy, which directs all state agencies to suspend any ties to Russian government-backed business and financial institutions. This Order requires a temporary revocation of any contact, permit, or license currently issued to Russian- or Belarusian-controlled companies. However, the scope of tools available for states are largely symbolic, as excessive state bans of Russian-made goods and sanctions of pension funds could violate international laws and trade agreements. 

Implications and Trends

Impact on the Russian Economy 

Russian markets and the ruble have already seen a decline following these sanctions. Overall, the ruble is still down, trading on 3/10 at 133 to the dollar, a decline of 40% since the West took action on SWIFT. U.S. officials have stated the sanctions were designed for the ruble to go into “free fall” and to promote soaring inflation in the Russian economy. Therefore, these economic downfalls may ultimately lead to hurting the Russian economy, Russian elites, and average Russian citizens. 

Russia’s Central Bank aimed to address the ruble’s downfall by increasing Russia’s benchmark interest rate to 20% from 9.5%. This hike was designed to incentivize Russians to keep cash in Russian banks. Additionally, this shake-up to Russian markets led to the Russian Central Bank keeping the Moscow Exchange closed on Monday, 2/28, and remaining closed for over a week through 3/10 – a sign the Bank may be running out of options.

On February 28, U.S. government regulators said the U.S. financial system was functioning “in a normal manner.” The Financial Stability Oversight Council (FSOC), comprised of the Treasury Department, the Federal Reserve, the Securities and Exchange Commission, and other major U.S. financial regulators, convened an unscheduled, closed-door meeting to discuss the effects of the sanctions. Additionally, the FSOC said it would continue to monitor financial developments. As of 2:15 p.m., the 10-year Treasury is at 2.04%, up 5.6 basis points; and 30 year is trading at 2.38%, up 7.8 basis points.

Additional Targets for Sanctions

At the onset of this crisis, the U.S. Treasury Department’s Office of Foreign Asset Control (OFAC) was granted the authority to designate for sanctions any Russian financial institution, so additional financial institutions are likely to be targeted as the United States seeks to increase pressure on Russia. Additional sanctions and visa restrictions are also expected against a broader range of Russian political and economic elites. 

The U.S. also has not significantly targeted the commodities trade, currently allowing base materials to flow out of Russia but imposing restrictions on final products flowing into Russia. While the commodities trade will be impacted by significant sanctions targeting some Russian banks – as well as recent Russian action to prevent the flow of currency out of Russian borders – there is not much indication the United States is intending to impose sanctions on these sectors at this time. However, calls from Congress to address the U.S. trade approach to Russia are growing, with some calling for legislation allowing the administration to increase tariffs on any import from Russia.

International Pressure

The United States, EU, and UK have been remarkably united in their efforts to impose massive costs on Russia without military intervention, forming a broad and deep coalition to ensure Russia cannot easily circumvent sanctions and restrictions. Other countries are feeling pressure to “pick a side,” as the United States is unreceptive to countries waiting to see how the conflict progresses. 

However, a short list of countries have been vocal in opposition to the concerted international efforts. Most notably, China has repeatedly called the sanctions regime illegal and implied they were unilateral, with a Chinese Foreign Ministry spokesperson stating, “The position of the Chinese government is that we believe that sanctions have never been a fundamental and effective way to solve problems.” China has stopped short of endorsing Russia’s invasion, stating that the current situation “is not something we want to see” but has argued that Russia’s “legitimate security demands should be taken seriously and properly addressed.” Given the lack of respect China has for U.S. sanctions regimes, China will be the largest market for Russia to turn to as economic costs accrue. 

Private Sector Action

Private sector and civil society pressure is increasing significantly as well, with international athletic organizations banning Russian athletes from participation in international events, major international companies ending joint ventures and divesting from investments (to name a few: BP divested from Rosneft, Shell ended its JV with Gazprom, Maersk suspended most transport to and from Russia, Warner Media pulled a movie from release in Russia, Disney indefinitely suspended all releases in Russia, YouTube banned several Russian media outlets, and Apple stopped Apple Pay service in Russia, geo-restricted Russian media apps, and ended the sale of personal devices in Russia). There are also anecdotal reports of liquor stores in the United States and Canada pulling Russian-made products from their shelves.

Several major credit card operators, including American Express, Visa, and Mastercard, also announced they would suspend operations in Russia – actions that President Biden directly praised. Once a symbol of the reintegration with the West, McDonalds has also announced they will temporarily close operations in Russia as well. Several Western media outlets, including the BBC and The New York Times, have also ceased their Russia operations over concerns for employee safety. Several financial institutions, including JP Morgan Chase and Goldman Sachs have announced they are winding down their operations in Russia, while many e-commerce and retail companies are suspending shipments to Russia and Belarus. Several prominent western consultancies are reducing their Russian footprint or withdrawing entirely, with KPMG and PwC some spinning off their Russia operations into independent entities, severing them from their networks. As reports of indiscriminate Russian attacks on civilians increase, public pressure for further private sector action could grow.

Cybersecurity 

While Russia has not yet used its cyber capabilities to respond to U.S. or partner actions, or even to a significant degree in Ukraine, Russia maintains significant capabilities in this space. This remains a key concern for U.S. cyber agencies and our allies who have sought to isolate Russia. Public and private agencies are warning U.S. companies and citizens from increased threats of cyberattacks from Russia. The U.S. Cybersecurity and Infrastructure Security Agency (CISA) has warned that cyberattacks are likely to occur and “unintentionally spill over to organizations in other countries.”  This has led to a widespread message for entities to improve cyber defenses, especially as attacks and counterattacks could emerge in the coming days. 

Many financial institutions have begun aggressively financing to ensure the safety and effectiveness of their data and computer protection mechanism. Additionally, some agencies have offered free services to help entities protect against any emerging threats. Lastly, Congress could very well advance a cybersecurity package that would increase funding and tools to protect against cyber warfare.

Congressional Action

Members of Congress have sought to help shape the U.S. response from the outset of the crisis, with several legislative efforts introduced in December 2021 and January 2022 intended to deter a Russian invasion. However, disagreements between members prevented Congress from coming to consensus before Russia invaded. Since the invasion, and in part due to the significant sanctions already imposed against Russia, Congress has largely been considering other measures beyond sanctions and is working to support additional assistance to Ukraine.

On Thursday, 3/10, the Senate passed and sent to President Biden to be signed into law the FY22 Omnibus, which had passed the House on 3/9. This government funding legislation includes a supplemental appropriations act for Ukraine, providing $13.6 billion in emergency funding. These funds are focused across four areas: humanitarian assistance, defense assistance, economic assistance, and sanctions enforcement. It would authorize over $3 billion for European Command operations mission support, the deployment of personnel to the region, and intelligence support; increase the President’s authority to transfer defense equipment to Ukraine and other allies to $3 billion; and reinforce NATO’s flank through an additional $650 million for the Foreign Military Financing program. Additionally, it authorizes $2.65 billion through USAID for humanitarian assistance and $1.4 billion for migration and refugee assistance for those fleeing Ukraine. It also provides $1.8 billion for economic support for Ukraine and its neighbors, including for use on energy issues, and provides $145 million to counter disinformation and support local actors, including activists and independent media. Finally, the bill would provide funding for the Commerce, Justice, and Treasury Departments to ensure they have the resources to enforce sanctions and respond to cyber threats.

Along with the omnibus, House Speaker Nancy Pelosi (D-CA) led the passage in the House of the Suspending Energy Imports from Russia Act, which would ban the importation of Russian energy products, require the United States to advocate for suspending Russia’s participation at the WTO, and reauthorize the Global Magnitsky Act to allow the Biden administration to hold accountable human rights abusers and corrupt actors around the globe. Republicans in the House expressed disappointment that the House version of this bill – unlike the bipartisan Senate version – did not address the Permanent Normal Trade Relations status that Russia currently enjoys. President Biden later signaled Pelosi held off on addressing PNTR to provide time for the administration to work with allies for joint action on trade status. The House insisted on passing this legislation despite action by President Biden to prohibit energy imports through executive order.

As the U.S. government takes additional steps, BGR will provide further updates on the actions and their impacts.

Sanctioned Financial Institutions

  • VEB (2/22)
  • Promsvyazbank (2/22)
  • Sberbank (2/24)
  • VTB (2/24)
  • Otkritie (2/24)
  • Novikom (2/24)
  • Sovcom (2/24)
  • Central Bank (2/28) 
  • National Wealth Fund of the Russian Federation (2/28) 
  • Russian Direct Investment Fund (RDIF) (2/28)

Additional Sanctioned Entities

  • Nord Stream 2 AG (2/23)
  • Limited Liability Company Atlant S (2/24)
  • Limited Liability Company Inspira Invest A (2/24)
  • Ministry of Finance of the Russian Federation (2/28) 
  • Altitude X3 (3/3)
  • Avanfort OOO (3/3)
  • AO Aviastar-SP (3/3)
  • Design Bureau of Special Machine Building (3/3)
  • Firma Veardon OOO (3/3)
  • Geopolitica (3/3)
  • Irkutsk Aviation Plant (3/3)
  • Izhevsk Unmanned Systems Research And Production Associated Limited Liability Company (3/3)
  • JSC Avangard (3/3)
  • Federal Scientific And Production Center Titan Barrikady (3/3)
  • AO Odk-Klimov (3/3)
  • Kolomna Machine Building Design Bureau (3/3)
  • Salavat Chemical Plant (3/3)
  • Jounral Kamerton (3/3)
  • Central Scientific Research Institute Of Automation And Hydraulics (3/3)
  • JSC Novosibirsk Aircraft Production Association Plant (3/3)
  • JSC Research And Production Association Kvant (3/3)
  • Katina D.O.O. (3/3)
  • Komsomolsk-On-Amur Aviation Plant (3/3)
  • Kurganmashzavod (3/3)
  • Lakhta Park Premium, OOO (3/3)
  • Lakhta Park, OOO (3/3)
  • Lakhta Plaza, OOO (3/3)
  • Nemchinovo Investments OOO (3/3)
  • LLC Ostozhenka 19 (3/3)
  • Makeyev State Missile Center (3/3)
  • New Eastern Outlook (3/3)
  • Nizhniy Novgorod Sokol Aircraft Manufacturing Plant (3/3)
  • ODK-Saturn PAO (3/3)
  • Odna Rodyna (3/3)
  • Oriental Review (3/3)
  • Kuznetsov ODK (3/3)
  • Public Joint-Stock Company Odk-Ufimskoye Motorostroitelnoye Production Association (3/3)
  • Radioavtomatika LLC (3/3)
  • Rhythm of Eurasia (3/3)
  • Sova Nedvizhimost OOO (3/3)
  • T.G.A. D.O.O. (3/3)
  • The Planar Company (3/3)
  • United World International (3/3)
  • All-Russian Scientific Research Institute Of Aviation Materials (3/3)
  • Zareche-4 OOO (3/3)
  • SMP Bank (3/3)
  • Apollon OOO (3/11)
  • RK Briz, OOO (3/11)
  • Zeel-M Co. Ltd. (3/11)

Sanctioned Persons

  • Denis Aleksandrovich Bortnikov (2/22)
  • Aleksandr Vasilievich Bortnikov (2/22)
  • Petr Mikhailovich Fradkov (2/22)
  • Vladimir Sergeevich Kiriyenko (2/22)
  • Sergei Vladilenovich Kiriyenko (2/22)
  • Michael Warnig (2/23)
  • Sergei Sergeevich Ivanov (2/24)
  • Sergei Borisovich Ivanov (2/24)
  • Andrey Patrushev (2/24)
  • Nikolai Platonovich Patrushev (2/24)
  • Ivan Igorevich Sechin (2/24)
  • Igor Ivanovich Sechin (2/24)
  • Alexander Aleksandrovich Vedyakhin (2/24)
  • Andrey Sergeyevich Puchkov (2/24)
  • Yuriy Alekseyevich Soloviev (2/24)
  • Galina Olegovna Ulyutina (2/24)
  • Vladimir Putin (2/25) 
  • Sergei Lavrov (2/25) 
  • Valery Gerasimov (2/25) 
  • Sergei Shoigu (2/25) 
  • Kirill Aleksandrovich Dmitriev (2/28) 
  • Nikolai Tokarev (3/3)
  • Galina Tokarev (3/3)
  • Mayya Tokarev (3/3)
  • Boris Rotenberg (3/3)
  • Karina Rotenberg (3/3)
  • Roman Rotenberg (3/3)
  • Boris Rotenberg (3/3)
  • Arkady Rotenberg (3/3)
  • Pavel Rotenberg (3/3)
  • Igor Rotenberg (3/3)
  • Liliya Rotenberg (3/3)
  • Sergei Chemezov (3/3)
  • Yekaterina Chemezov (3/3)
  • Stanislav Chemezov (3/3)
  • Anastasiya Chemezov (3/3)
  • Igor Shuvalov (3/3)
  • Olga Shuvalov (3/3)
  • Evengy Shuvalov (3/3)
  • Maria Shuvalov (3/3)
  • Yevgeniy Prigozhin (3/3)
  • Polina Prigozhin (3/3)
  • Lyubov Prigozhin (3/3)
  • Pavel Prigozhin (3/3)
  • Dmitry Peskov (3/3)
  • Alisher Usmanov (3/3)
  • Yuriy Vyacheslavovich Afonin (3/11)
  • Yuriy Nikolaevich Andresov (3/11)
  • German Valentinovich Belous (3/11)
  • Yevgeniy Ivanovich Bessonov (3/11)
  • Aleksandr Aleksandrovich Chasovinikov (3/11)
  • Olga Konstantinovna Dergunova (3/11)
  • Natalia Germanova Dirks (3/11)
  • Aleksandr Andreyevich Gayevoy (3/11)
  • Elena Aleksandrovna Georgieva (3/11)
  • Leonid Ivanovich Kalashnikov (3/11)
  • Vladimir Ivanovich Kashin (3/11)
  • Vladimir Nikolaevich Knyaginin (3/11)
  • Nikolay Vasilievich Kolomeitsev (3/11)
  • Maxim Dmitrievich Kondratenko (3/11)
  • Boris Yurievich Kovalchuk (3/11)
  • Kira Valentinovna Kovalchuk (3/11)
  • Stepan Kirillovich Kovalchuk (3/11)
  • Tatyana Aleksandrovna Kovalchuk (3/11)
  • Vadim Valerievich Kulik (3/11)
  • Aleksey Vladimirovich Kurinniy (3/11)
  • Valerii Vasilyevich Lukyanenko (3/11)
  • Ivan Ivanovich Melnikov (3/11)
  • Tatiana Aleksandrovna Navka (3/11)
  • Erkin Rakhmatovich Norov (3/11)
  • Dmitriy Georgievich Novikov (3/11)
  • Nikolay Ivanovich Osadchiy (3/11)
  • Svyatoslav Evgenievich Ostrovsky (3/11)
  • Anatolii Yuryevich Pechatnikov (3/11)
  • Nikolay Peskov (3/11)
  • Elizaveta Dmitriyevna Peskova (3/11)
  • Dmitrii Vasilyevich Pyanov (3/11)
  • Andrey Yurievich Sapelin (3/11)
  • Kazbek Kutsukovich Taysaev (3/11)
  • Dmitri Nikolaevich Vavulin (3/11)
  • Gennady Andreyevich Zyuganov (3/11)

Disinformation Sanctions

  • Svetlana Georgiyevna Zamlelova (3/3)
  • Vladimir Ilich Maksimenko (3/3)
  • Andrey Grigoryevich Areshev (3/3)
  • Irina Sergeyevna Bubnova (3/3)
  • Anton Sergeyevich Bespalov (3/3)
  • Sergei Ivanovich Saenko (3/3)
  • Natalya Petrovna Skorokhodova (3/3)
  • Yuriy Anatolyevich Prokofyev (3/3)
  • Andrey Vitalyevich Ilyashenko (3/3)
  • Anastasiya Sergeyevna Kirillova (3/3)
  • Maksim Borisovich Krasovskiy (3/3)
  • Nina Viktoronova Dorokhova (3/3)
  • Yevgeniya Vitalyevna Nezhdanova (3/3)
  • Aleksandra Aleksandrovna Kamyshanova (3/3)
  • Denis Sergeyevich Tatarchenko (3/3)
  • Maksim Iosifovich Krans (3/3)
  • Valeriy Ivanovich Pogrebenkov (3/3)
  • Konstantin Sergeyevich Knyrik (3/3)
  • Yuriy Sergeyevich Fedin (3/3)
  • Mikhail Anatolyevich Sinelin (3/3)
  • Yevgeniy Eduardovich Glotov (3/3)
  • Denis Yakovlevich Gafner (3/3)
  • Aelita Leonidovna Mamakova (3/3)
  • Aleyona Anatolyevna Chuguleva (3/3)
  • Valeriya Kalabayeva (3/3)
  • Darya Aleksandrovna Dugina (3/3)

Debt and Equity Prohibitions

  • Sberbank (2/24)
  • Gazprombank (2/24)
  • Russian Agricultural Bank (2/24)
  • Gazprom (2/24)
  • Gazprom Neft (2/24)
  • Transneft (2/24)
  • Rostelecom (2/24)
  • RusHydro (2/24)
  • Alrosa (2/24)
  • Sovcomflot (2/24)
  • Russian Railways (2/24)
  • Alfa-Bank (2/24)
  • Credit Bank of Moscow (2/24) 

Sanctioned Boats and Aircraft

  • Dilbar (yacht) (3/3)
  • LX-MOW (aircraft) (3/3)
  • M-IABU (aircraft) (3/3)
  • Tango (yacht) (3/11)
  • P4-MIS (aircraft) (3/11)

DISCLAIMER: This memorandum only reflects policy and political observations and does not constitute legal advice. We recommend seeking advice from legal counsel or compliance officers if you have any questions or concerns regarding compliance with U.S. restrictions. Last Updated: March 11, 2022