On Second Anniversary of Russia’s Further Invasion of Ukraine and Following the Death of Aleksey Navalny, Treasury Sanctions Hundreds of Targets in Russia and Globally

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TURBOFAC Commentary (262 words)

Notes:

1) On 2-23-24, OFAC and the State Department designated hundreds of entities pursuant to 14024. There were many non-Russian entities designated for “operating in” various targeted sectors of the Russian economy, but these designations all appear to fall within the realm of “de facto secondary sanctions actions” as described at Introductory Note Common to all Derivative Designation Notices Included in the Research System. More specifically in the OFAC Press Release (On Second Anniversary of Russia’s Further Invasion of Ukraine and Following the Death of Aleksey Navalny, Treasury Sanctions Hundreds of Targets in Russia and Globally), OFAC refers to the “Annex 3” targets as those ”who facilitate, orchestrate, engage in, and otherwise support the transfer of critical technology and equipment to Russia’s military-industrial base.” Similarly, the State Department Fact Sheet (Responding to Two Years...

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On Second Anniversary of Russia’s Further Invasion of Ukraine and Following the Death of Aleksey Navalny, Treasury Sanctions Hundreds of Targets in Russia and Globally

TURBOFAC Commentary (262 words)