On April 15, 2021, the Biden administration issued a new executive order creating broad authority to impose blocking sanctions against a wide range of individuals and entities determined to be engaged in “harmful foreign activities” of the Russian Federation.
In parallel with and under the authority of the New EO, the U.S. Department of the Treasury, Office of Foreign Assets Control issued a new directive prohibiting U.S. financial institutions from participating in the primary market for ruble-denominated sovereign debt or from otherwise lending funds to the Russian Federation, effective June 14, 2021. (Non-ruble Russian sovereign debt and funding have been prohibited under an existing 2019 ban, described in our previous post and below.) As part of “a new U.S. campaign against Russian malign behavior” under the New EO and existing authorities, OFAC also designated over 40 individuals and entities alleged to have attempted to influence the 2020 U.S. presidential election or to be operating in the Crimea region.
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