On July 16, 2014, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) imposed an additional wave of sanctions against Russian entities in the financial, energy, and defense sectors.  OFAC established a new Sectoral Sanctions Identifications List (the “SSI List”), which identifies two Russian financial institutions and two Russian energy companies for targeted sanctions.  Simultaneously, OFAC announced the addition of five individuals and 11 entities to the List of Specially Designated Nationals and Blocked Persons (the “SDN List”). The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) added the same 11 entities to its Entity List.

The highly anticipated sectoral sanctions target Russian banks Gazprombank OAO and Bank for Development and Foreign Economic Affairs State Corporation (otherwise known as “VEB”), and Russian energy firms Rosneft Oil Company and OAO Novatek.  These four parties are not subject to comprehensive blocking measures; rather, the new sanctions prohibit U.S. persons and persons in the United States from dealing in certain new debt of these parties and, in the case of the two banks, new equity. These targeted sanctions were authorized by the Secretary of the Treasury under Executive Order 13662, which was signed by the President in March.

The new additions to the SDN List include eight Russian arms firms, three parties asserting unauthorized governmental control over parts of Ukraine, one entity allegedly involved in the misappropriation of Ukrainian state assets, and four Russian government officials.

At the same time, the European Council has taken action to expand the EU sanctions relating to the Ukraine crisis.  It has added 11 additional individuals to the sanctions list.  It has agreed to take additional measures in the near term to expand the EU sanctions list and to impose certain investment- related sanctions targeting Russia and Crimea.