Background

The Treasury Department’s Office of Foreign Assets Control has issued the Russian Harmful Foreign Activities Sanctions Regulations to implement Executive Order 14024 of April 15, 2021. These regulations, which are effective as of March 1, include provisions on prohibited transactions, licenses, authorizations, licensing policy, penalties, reports, and procedures.

EO 14024 cited the following as harmful foreign activities by the Russian government: efforts to undermine the conduct of free and fair democratic elections and democratic institutions in the U.S. and its allies and partners, engaging in and facilitating malicious cyber-enabled activities against the U.S. and its allies and partners, fostering and using transnational corruption to influence foreign governments, pursuing extraterritorial activities targeting dissidents or journalists, undermining security in countries and regions important to U.S. national security, and violating well-established principles of international law, including respect for the territorial integrity of states.

OFAC states that these regulations are being published in abbreviated form to provide immediate guidance to the public and that it intends to supplement this rule with a more comprehensive set of regulations that may include additional interpretive guidance and definitions, general licenses, and other regulatory provisions.

For more information on these regulations and the trade-related prohibitions they include, please contact attorney Kristine Pirnia via email.

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