Treasury Sanctions 50 Worldwide for Ties to Russian Military-Industrial Complex

On November 14, 2022, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) added 14 individuals, 28 entities, and 8 aircraft to the Specially Designated Nationals and Blocked Persons List (SDN List).  The additions were described as a a pair of transnational networks that support the Russian military-industrial complex through procuring technology and otherwise financially enabling previously sanctioned parties.

In addition to Russia, sanctioned entities are located in Armenia, British Virgin Islands, France, Germany, Luxembourg, Malta, Spain, Switzerland, Taiwan, and the UAE.  Eight aircraft in which a Malta and Russia-based company has an interest were also designated, with a new General License 40C related to the safety of civil aviation.  Sanctions also apply to a number of relatives of sanctioned individuals.

OFAC published a press release on this action which includes additional background and identifying information on the sanctioned individuals, entities, and aircraft.

This action serves as an important reminder that not only does the SDN list change frequently, but screening only for parties in countries of concern is not adequate for export compliance.  Sanctions directed at one country, such as Russia, may ensnare entities worldwide that are doing business with the sanctioned country.