Beginning February 21, the U.S. Department of the Treasury’s Office of Foreign Assets Control has issued significant sanctions in response to the Russian Federation’s military invasion of Ukraine and its recognition of Ukraine’s separatist regions.

Since Buckley’s last update on February 25, there have been a number of developments in the sanctions against Russia, which include:

• A prohibition on the importation into the United States of Russian crude oil and certain petroleum products, liquified natural gas, and coal
• A ban on new investment by U.S. persons in the Russian energy sector
• The imposition of asset blocking sanctions on Vladimir Putin, Sergei Lavrov, numerous oligarchs and families with ties to Putin, and Russian-backed disinformation services
• Sanctions targeting Russia’s U.S. foreign reserves by prohibiting all dealings with Russia’s Central Bank, National Wealth Fund, and Ministry of Finance
• The issuance of the Russian Harmful Foreign Activities Sanctions Regulations, which codify the prohibitions imposed under Executive Order 14024, discussed below, and include several interpretations and general licenses
• The issuance of a general license that exempts “transactions related to energy” from certain prohibitions imposed under Executive Order 14024