New U.S. Sanctions of October 30, 2024

On October 30, 2024, the U.S. Department of the Treasury imposed sanctions on 275 individuals and entities involved in supplying advanced technology and equipment to Russia’s military-industrial complex, as well as engaging in other transactions or providing services prohibited by U.S. sanctions. The individuals and entities indicated in the published list by the Department of the Treasury’s Office of Foreign Assets Control (OFAC) are now officially considered to be the Specially Designated Nationals (SDN) – the U.S. sanctions violators with all associated consequences.

U.S. Sanctions Violators in Third Countries

Notably, the sanctions are targeted at both individuals and companies, as well as “extensive networks” facilitating sanctions evasion across 17 countries, including India, China, Switzerland, Thailand, Turkey, Hong Kong, Benin, and Montenegro. The objective of these new measures is to block supply routes to Russia for “tools and technologies” used by the Russian military-industrial complex to continue its war efforts in Ukraine. OFAC has also targeted entities in third countries involved in various schemes to evade or bypass U.S. sanctions by supplying dual-use goods. As part of these measures, more than 120 individuals and entities have been added to the U.S. sanctions list.

Sanctions Against the Russian Military-Industrial Complex

The new OFAC sanctions list includes more than 150 Russian military enterprises, as well as companies that procure or produce military materials and technologies, including those related to the aerospace industry. Among them are two companies within the structure of Rosatom: “Rosatom Digital Solutions” and “Rosatom Microelectronics,” as well as the Moscow Aviation Institute (MAI). Among the individuals included in the OFAC SDN List are five deputy ministers of defense of the Russian Federation, the CEO of Transmashholding, as well as other citizens of Russia, Belarus, India, China, Turkey, Switzerland, and Chile.

U.S. Sanctions Violators in the Provision of Trust and Corporate Services 

The OFAC sanctions list also includes foreign individuals and legal entities for providing trust and corporate services to Russian clients. This is due to the fact that these individuals effectively perform the functions of financial intermediaries, often playing a key role in creating and servicing extensive networks aimed at circumventing sanctions. U.S. sanctions violators in the area of trust and corporate services have attracted attention because, according to the U.S. Department of the Treasury, they are not only involved in creating and servicing certain structures to evade sanctions but also act as those who provide a multiplying effect resulting from the coordinated actions of individual companies united in network structures. Individuals and legal entities from Switzerland, Thailand, and the Bermuda Islands have also been sanctioned as part of these measures.

Conclusion

As always, in such situations, all property and assets of the U.S. sanctions violators – individuals and companies listed on the OFAC SDN List – that are in the possession or under the control of U.S. individuals or entities are subject to blocking from this day forward. Additionally, any organizations in which sanctioned persons own at least 50% “individually or in the aggregate, directly or indirectly” are also subject to blocking. All transactions involving any participation by U.S. persons or having a connection to U.S. territory are prohibited. Exceptions are possible only if explicitly authorized by a general or specific OFAC license. Non-U.S. individuals and entities are also prohibited from violating U.S. sanctions, including participating in any actions or schemes to circumvent the sanctions.

If you or your interests have been affected by U.S. sanctions, please contact us. We will quickly assess the situation and offer a solution.