US sanctions Russian oligarchs, gov officials, and entities for international ‘malign activity’

US-Russia.jpgToday, OFAC has designated a number of Russian individuals and entities (asset freezes and travel bans imposed) on the basis that they have been involved in a range of “malign activity around the globe”. The designations include:

  • 7 Russian oligarchs – Vladimir Bogdanov, Oleg Deripaska, Suleiman Kerimov, Igor Rotenberg, Kirill Shamalov, Andrei Skoch, and Viktor Vekselberg – as well as 12 companies owned or controlled by them;
  • 17 Russian government officials; and
  • The Russian state-owned weapons trading company Rosoboroneksport, and its Russian subsidiary bank, Russian Financial Corporation Bank (Russia-Syria related designations).

The Russian oligarchs and government officials sanctioned today follow the US Treasury’s CAATSA Section 241 Report, issued in late January 2018 (see previous blog here). That Report identified 114 “senior foreign political figures” and 96 “oligarchs” in the Russian Federation (determined by their “closeness to the Russian regime and their net worth”).

Non-US persons may be liable for knowingly facilitating “significant transactions” for or on behalf of the individuals and entities sanctioned today.

OFAC has also issued 2 general licences to “minimize immediate disruptions to U.S. persons, partners, and allies”, see General Licences 12 and 13, as well as related FAQs. Links to the OFAC Notice and US Treasury press release.

This entry was posted in Russia, Syria, USA by Michael O'Kane. Bookmark the permalink.

About Michael O'Kane

Michael O’Kane is a partner and Head of the Business Crime team at leading UK firm Peters & Peters. Described as ‘first-rate’ (Legal 500 2012), he “draws glowing praise from commentators” (Chambers 2013) for handling the international aspects of business crime, including sanctions, extradition and mutual legal assistance. Called to the Bar in 1992 and prior to joining Peters & Peters he was a senior specialist prosecutor at the Crown Prosecution Service Headquarters(CPS). At CPS HQ he was a key member of a small specialist unit responsible for the prosecution of serious and high profile fraud, terrorist and special interest criminal matters including the Stansted Airport Afghan hijacking and the prosecution of Paul Burrell (Princess Diana’s butler). Michael joined Peters & Peters in 2002. He became a partner in May 2004, and Head of the Business Crime team in May 2009. Since joining Peters & Peters, Michael has dealt with a wide range of business crime matters. He has particular expertise in international sanctions, criminal cartels, extradition, corruption, mutual legal assistance, and FSA investigations. Described as“ an influential practitioner in fraud and regulatory work, so much so that he is top of the referral lists of many City firms for independent advice for directors” (The Lawyer’s Hot 100 2009), he was recognised as one of the UK’s most innovative lawyers in the 2011 FT Innovative Lawyer Awards and included in the list of the UK's leading lawyers in 'The International Who's Who of Asset Recovery 2012. In 2012 he was the winner of the Global Competition Review Article of the Year. Michael regularly appears on television and radio to discuss his specialist areas and he is the author of the leading textbook on the UK Criminal Cartel Offence “The Law of Criminal Cartels-Practice and Procedure” (Oxford University Press 2009). Recent/Current Sanctions Work • Representing 109 individuals and 12 companies subject to designation by the European Council under targeted measures imposed against Zimbabwe. This is the largest and most complex collective challenge to a sanctions listing ever brought before the European Court. • Acting for a former Egyptian Minister and his UK resident wife, challenging their designation by the European Council of Ministers under targeted measures brought against former members of the Egyptian Government. • Advising a company accused in a UN investigation report to have breached UN sanctions imposed in relation to Somalia. • Advising a UK company in relation to ongoing commercial relationships with an Iranian company listed under both EU and UN sanctions. • Advising an individual in relation to a UK investigation for alleging breaching nuclear export controls.

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