On September 1, 2016, the US Department of the Treasury's Office of Foreign Assets Control (OFAC) added 37 Russian and Ukrainian individuals and entities to the List of Specially Designated Nationals and Blocked Persons (SDN List) and identified certain subsidiaries of entities included on the Sectoral Sanctions Identifications List (SSI List). OFAC also issued General License No. 10, which authorizes certain transactions that are ordinarily incident and necessary for US persons and non-US persons to divest or transfer holdings in the Russian construction company PJSC Mostotrest to a non-US person.
New Additions to the Specially Designated Nationals List
The United States announced 37 additional designations to the SDN List.
Seventeen Ukrainian separatists were designated for being responsible for or complicit in actions or policies that threaten the peace, security, stability, sovereignty, or territorial integrity of Ukraine; asserting governmental authority over a part or region of Ukraine without the authorization of the Government of Ukraine; or for acting for or on behalf of previously designated groups as leaders of such entities. An additional entity, Salvation Committee of Ukraine, was designated for being owned or controlled by, or acting for or on behalf of, directly or indirectly, former Ukrainian Prime Minister Mykola Azarov, who was previously designated for the misappropriation of state assets of Ukraine.
OFAC designated one Russian entity, ABR Management CJSC, for acting for or on behalf of, directly or indirectly, and materially assisting, sponsoring, or providing, financial, material, or technological support for, or goods or services to or in support of, Bank Rossiya.
OFAC additionally designated 19 construction, transportation, defense, and shipping entities for operating in the Crimea region of Ukraine.
All property and interests in property of these individuals and entities located in the United States or within the possession or control of a US person1, wherever located, are considered blocked and may not be dealt in. Any entity in which a blocked person holds a 50 percent or greater ownership interest is itself considered blocked by operation of law. US persons may not engage in any dealings, directly or indirectly, with blocked persons. Provision of goods, services or support for blocked parties is identified as a criterion for potential future designation.
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1 A US person is defined to include any United States citizen, permanent resident alien, entity organized under the laws of the United States or any jurisdiction within the United States (including foreign branches), or any person in the United States.
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