US marks Navalny death and invasion anniversary with sanctions slew

At the end of last week, the White House announced 500 new sanctions on Russia, including restrictions on transacting with nearly 100 entities allegedly providing secret support to the Kremlin.

President Joe Biden unveiled the latest US actions to coincide with the second anniversary of the Ukraine invasion on 24 February and to punish Moscow for the death of opposition politician and activist Alexei Navalny in a Kremlin prison.

‘These sanctions will target individuals connected to Navalny’s imprisonment as well as Russia’s financial sector, defense industrial base, procurement networks and sanctions evaders across multiple continents,’ Biden said in a 23 February statement. ‘We are also imposing new export restrictions on nearly 100 entities for providing backdoor support for Russia’s war machine. We are taking action to further reduce Russia’s energy revenues. And I’ve directed my team to strengthen support for civil society, independent media, and those who fight for democracy around the world.’

The actions have been taken both by the US Office of Foreign Assets Control (‘OFAC’) at the US Treasury, and by the US Department of Commerce’s Bureau of Industry and Security (‘BIS’). For its part, OFAC announced a slew of new designations under various headings including Russia’s financial infrastructure:

• ‘Russia’s core financial infrastructure, including the operator of the Mir National Payment System and Russian banks, investment firms, and financial technology (fintech) companies, to further implement G7 commitments to curtail Russia’s use of the international financial system to further its war against Ukraine.’
• ‘OFAC continues to target persons outside of Russia who facilitate, orchestrate, engage in, and otherwise support the transfer of critical technology and equipment to Russia’s military-industrial base.’
• The Alabuga UAV procurement network. OFAC says it is targeting ‘the network through which Russia has acquired and produced deadly unmanned aerial vehicles (UAVs) [noting that] Russia and Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL) have cooperated to finance and produce Iranian-designed one-way attack UAVs, also known as kamikaze drones, at a newly established a facility in Russia.’
• Russia’s military-industrial base. OFAC says, ‘As Russia’s overheating war economy continues to cannibalize non-defense-related production at the expense of future economic prospects for the Russian people, an increasing number of entities across Russia are directly or indirectly contributing to Russia’s war machine.’

Details of all the designations are included in a series of annexes. OFAC has also published details of wind-down licences, issued three new FAQs and amended others.

Coinciding with Biden’s statement, the Bureau of Industry and Security (‘BIS’) announced it is ‘adding an additional 93 entities under 95 entries (due to some entities operating in multiple countries) to the Entity List for a variety of reasons related to their activities in support of Russia’s defense-industrial sector and war effort.’

It said 63 of the entities are based in Russia, eight in China, 16 in Turkey, four in the United Arab Emirates (‘UAE’), two in the Kyrgyz Republic and one each in India and South Korea.