Treasury Imposes Sanctions on More Than 150 Individuals and Entities Supplying Russia’s Military-Industrial Base

Date issued: Dec. 12 2023

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TURBOFAC Commentary (321 words)

Consolidated comment on Treasury Imposes Sanctions on More Than 150 Individuals and Entities Supplying Russia’s Military-Industrial Base and Taking Additional Sweeping Measures Against Russia.

On 12-12-23, OFAC and the State Department, separately, designated dozens third-country entities for providing goods to Russian entities. The third-country entities were designated for “operating in” various sectors of the Russian economy, e.g. technology, manufacturing, electronics and aerospace, depending on the nature of the goods exported and end users.

See Introductory Note Common to all Derivative Designation Notices Included in the Research System, and query whether and to what extent any of these designations are the sort of “de facto secondary sanctions” actions described in the System Note. We generally exclude designations where there is an allegation of deceptive or evasive conduct or where the transaction involves the bulk shipment of...