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Thompson Hine LLP, a full-service business law firm with approximately 400 lawyers in 11 offices, was ranked number 1 in the category “Most innovative North American law firms: New working models” by The Financial Times and was 1 of 7 firms shortlisted for The American Lawyer’s inaugural Legal Services Innovation Award. The firm has been recognized by the National Law Journal as a Legal Technology Trailblazer and featured by Bloomberg for its innovative service delivery models, which drive accuracy and predictability. The firm’s commitment to innovation is embodied in Thompson Hine SmartPaTHTM – a smarter way to work – predictable, efficient and aligned with client goals. For more information, please visit ThompsonHine.com and ThompsonHine.com/SmartPaTH.

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On February 25, the Office of Foreign Assets Control (OFAC) placed on the Specially Designated Nationals (SDN) List Russian President Vladimir Putin, Foreign Minister Sergei Lavrov, Minister of Defense Sergei Shoigu and Chief of the General Staff of the Russian Armed Forces, First Deputy Minister of Defense, and General of the Army Valery Gerasimov.&nbsp; Specific detail on these designations is available <a href="https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220225_33">here</a>.
On February 28, 2022, OFAC <a href="https://home.treasury.gov/news/press-releases/jy0612">took further steps</a> to restrict Russia&rsquo;s access to the world&rsquo;s financial markets by sanctioning the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation. In addition, OFAC placed on the SDN List the Russian Direct Investment Fund (RDIF) and its Chief Executive Officer, Kirill Dmitriev.&nbsp; These actions restrict or, in certain circumstances, terminate these entities access to the U.S. financial system.&nbsp; With this announcement OFAC issued <a href="https://home.treasury.gov/system/files/126/eo14024_directive_4_02282022.pdf">Directive 4</a> under Executive Order 14024 prohibiting U.S. persons from engaging in any transactions with these Russian financial entities, including any transfer of assets to such entities or any foreign exchange transactions.&nbsp; <a href="https://home.treasury.gov/system/files/126/russia_gl8a_1.pdf">General License No. 8A</a>, however, will allow for limited continued transactions &ldquo;related to energy&rdquo; until June 24, 2022 with the Central Bank of Russia as well as certain other Russian financial institutions. &nbsp;Specific detail on these designations is available <a href="https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220228">here</a>.
With these designations to the SDN List, all property and interests in property of these persons that are in the United States or in the possession or control of U.S. persons (or their foreign branches) are blocked and must be reported to OFAC. In addition, any entities that are owned, directly or indirectly, individually or in the aggregate, 50% or more by one or more blocked persons are also blocked. &nbsp;Unless authorized by a general or specific license issued by OFAC, or exempt, all transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of blocked persons are generally prohibited. Dealings with blocked persons may also trigger reporting requirements pursuant to 31 C.F.R. &sect;&sect; 501.603 and 501.604.
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SmarTrade

Senior Legislative and Regulatory Policy Advisor

Scott E. Diamond

Partner

Francesca M.S. Guerrero

Samir D. Varma

International Trade

OFAC Sanctions Russian President Vladimir Putin and Additional Russian Financial Institutions