Responding to Two Years of Russia’s Full-Scale War On Ukraine and Navalny’s Death
FACT SHEET
OFFICE OF THE SPOKESPERSON
FEBRUARY 23, 2024
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DISRUPTING SANCTIONS EVASION AND BACKFILLING EFFORTS
The Department continues to disrupt the networks and channels through which Russia attempts to procure technology and equipment from third countries to support its war effort. Specifically, these designations target producers, exporters, and importers of items critical to Russia’s defense-industrial base, including common high-priority items identified by the U.S. Department of Commerce’s Bureau of Industry and Security, alongside the EU, UK, and Japan. Entities based in the PRC, Türkiye, and the United Arab Emirates, among other countries, continue to send these items and other important dual-use goods to Russia, including critical components that Russia relies on for its weapons systems. Many of these...
1) On 2-23-24, OFAC and the State Department designated hundreds of entities pursuant to EO 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...