Background

The State Department announced July 20 new sanctions on dozens of entities and individuals in connection with Russia’s ongoing war against Ukraine. According to State, these sanctions seek to curb the evasion of existing sanctions, degrade Russia’s current and future military capabilities, reduce its revenue from the metals and mining sector, and undermine its future energy capabilities.

One of the most common tactics Russian entities have used to continue their importation of foreign-made electronics and technology, State notes, is the use of third-party intermediaries and transshipment points outside of Russia. Entities based in the Kyrgyz Republic have been frequent exporters of controlled electronics components and other technology to Russia since its invasion of Ukraine, and some of these shipments have subsequently supplied sensitive dual-use goods to entities in Russia’s defense sector. State is therefore imposing sanctions on ten related entities and individuals as well as four others that have facilitated the evasion of existing sanctions.

State has also imposed sanctions on specified entities in Russia that import dual-use technology; produce munitions; operate in key industries such as aerospace, quantum technologies, advanced computing, energy, mining and metals, and manufacturing; or support Russia’s research and development of high-tech goods.

All property and interests in property of the designated persons that are in the U.S. or in the possession or control of U.S. persons are blocked and must be reported to the Office of Foreign Assets Control. Any entities that are owned, directly or indirectly, 50 percent or more by one or more blocked persons are also blocked.

All transactions by U.S. persons or within (or transiting) the U.S. that involve any property or interests in property of designated or blocked persons are prohibited unless exempt or authorized by a general or specific license issued by OFAC. These prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any blocked person and the receipt of any contribution or provision of funds, goods, or services from any such person.

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