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On August 20, 2021, the U.S. Department of the Treasury&rsquo;s Office of Foreign Assets Control (OFAC) implemented additional sanctions on Russia in response to the state-sponsored poisoning of Russian opposition leader Aleksey Navalny in August 2020. Specifically, OFAC has designating nine Russian individuals and two Russian entities found to be involved in Navalny&rsquo;s poisoning or Russia&rsquo;s chemical weapons program. Additionally, the U.S. Department of State has designated two Russian Ministry of Defense scientific laboratories that have engaged in activities to develop Russia&rsquo;s chemical weapons capabilities.
OFAC has placed the following <a href="https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20210820" target="_blank" rel="noopener">Russian entities and persons</a> on the Specially Designated Nationals (SDN) List:
<ul>
<li>FSB Criminalistics Institute&nbsp;&ndash; a sub-unit of the Federal Security Service of the Russian government (FSB).</li>
<li>State Institute for Experimental Military Medicine (GNII VM)&nbsp;&ndash; a scientific research organization specializing in security and defense that operates under the ultimate authority of the Russian Ministry of Defense.</li>
<li>Vladimir Bogdanov&nbsp;&ndash; Chief of the FSB&rsquo;s Special Technology Center.</li>
<li>Stanislav Makshakov&nbsp;&ndash; reportedly an FSB official and toxicologist.</li>
<li>Konstantin Kudryavtsev&nbsp;&ndash; an FSB Criminalistics Institute operative.</li>
<li>Alexey Alexandrov&nbsp; &ndash; an FSB Criminalistics Institute operative.</li>
<li>Ivan Osipov&nbsp;&ndash; an FSB Criminalistics Institute operative.</li>
<li>Vladimir Panyaev&nbsp;&ndash; an FSB operative.</li>
<li>Aleksei Sedov&nbsp;&ndash; Chief of the FSB&rsquo;s Service for the Protection of the Constitutional System and the Fight against Terrorism (also referred to as the FSB&rsquo;s 2nd Service).</li>
<li>Artur Zhirov&nbsp;&ndash; the former director of the 27th Scientific Center and a chemical weapons expert.</li>
<li>Kirill Vasiliev&nbsp;&ndash; the Director of the FSB Criminalistics Institute.</li>
</ul>
Effective immediately, all property and interests in property of these individuals and 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, U.S. persons are generally prohibited from engaging in transactions with these sanctioned individuals and entities. In addition, any entities that are owned, directly or indirectly, 50 percent or more by the designated persons and entities are also blocked.
The State Department has <a href="https://www.state.gov/fact-sheet-united-states-imposes-additional-costs-on-russia-for-the-poisoning-of-aleksey-navalny/" target="_blank" rel="noopener">designated</a> Russia&rsquo;s 27th Scientific Center and the 33rd Scientific Research and Testing Institute for operating in the defense and related materiel sector of the Russian Federation. These two entities were previously placed on OFAC&rsquo;s SDN List. As a result of these designations, the following sanctions will be applied under the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (CBW Act): (1) new and pending permit applications for the permanent importation of firearms and ammunition manufactured or located in Russia will be subject to a policy of denial; and, (2) additional Department of Commerce export restrictions on nuclear and missile-related goods and technology pursuant to the Export Control Reform Act of 2018.
For related past actions by the U.S. government towards Russia for its poisoning of Aleksey Navalny, see SmarTrade Update of <a href="https://www.thompsonhine.com/publications/united-states-implements-multiple-sanctions-and-export-restrictions-on-russia">March 8, 2021</a>.

core/freeform

SmarTrade

Senior Legislative and Regulatory Policy Advisor

Scott E. Diamond

International Trade

OFAC and State Department Sanction Additional Russian Entities and Persons for Poisoning of Aleksey Navalny   