Client Alert 11 Mar. 2022

U.S. President Biden Imposes Second Tranche of Economic Sanctions against Russia

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On February 24, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) released a second tranche of sanctions against Russian individuals and entities. These measures followed the comprehensive jurisdiction-based sanctions imposed on DNR and LNR on February 21, 2022, sanctions related to the Russian financial sector imposed on February 22, 2022, and sanctions on Nord Stream 2 G imposed on February 23, 2022.

The second tranche includes two new directives. OFAC Directive 2, issued under E.O. 14024, prohibits U.S. financial institutions from opening or maintaining a correspondent account or payable-through account for or on behalf of PJSC Sberbank of Russia and 25 of its subsidiaries, effective March 26, 2022. Processing transactions involving Sberbank and its subsidiaries is also prohibited. OFAC may designate other foreign financial institutions under Directive 2. Sanctions against such financial institutions shall become effective 30 days after the designation.

OFAC Directive 3, also issued under E.O. 14024, prohibits U.S. persons from engaging in all transactions in, providing financing for, and other dealings in new debt of longer than 14 days’ maturity or new equity issued on or after 12:01 a.m. Eastern Daylight Time, March 26, 2022, by 13 Russia-related entities:

  • Credit Bank of Moscow PJSC
  • Gazprombank JSC
  • JSC Alfa-Bank
  • JSC Russian Agricultural Bank
  • JSC Sovcomflot
  • OJSC Russian Railways
  • PJSC Alrosa
  • PJSC Gazprom
  • PJSC Gazprom Neft
  • PJSC Rostelecom
  • PJSC RusHydro
  • PJSC Sberbank of Russia
  • PJSC Transneft

OFAC defines debt to include “bonds, loans, extensions of credit, loan guarantees, letters of credit, drafts, bankers acceptances, discount notes or bills, or commercial paper” and equity to include “stocks, share issuances, depositary receipts, or any other evidence of title or ownership.”

OFAC may designate other foreign entities under Directive 3, which will be named on OFAC’s CAPTA List. Sanctions against such financial institutions shall become effective 30 days after the designation.

Additions to the SDN List

On February 24, 2022, OFAC also added approximately 70 individuals and entities to the SDN List pursuant to E.O. 14024. A full list is available here.


The U.S. Department of Justice announced a new task force aimed at enforcing sanctions on Russian oligarchs. Task Force KleptoCapture will be led by Andrew Adams, a veteran Assistant U.S. Attorney for the Southern District of New York. The interagency law enforcement group will be responsible for investigating and prosecuting sanctions violations.

The task force will be run out of the Office of the Deputy Attorney General, and will include attorneys from the National Security, Criminal, Tax and Civil Divisions of the Department of Justice, as well as from U.S. Attorneys’ Offices across the country. The task force will also include agents and analysts from the Federal Bureau of Investigation, the U.S. Marshals Service, the Internal Revenue Service, the Postal Inspection Service, the Department of Homeland Security, the Secret Service, and other agencies.

The Department of Justice announced that Task Force KleptoCapture will cooperate with a transatlantic task force that was announced by President Biden and European allies on February 26, 2022.

No further information about the transatlantic task force has been made available.