Sanctions Round Up First Quarter 2022

Shearman & Sterling LLP

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RUSSIA 1 Sanctions have been front and center this quarter following Russia's invasion of Ukraine in late February. The On January 20, OFAC designated four Ukrainian individuals for engaging in government-directed "influence US and Western Allies Unite in Opposition to Russian Aggression Against Ukraine sanctions and trade restrictions on Russia to pressure President Putin to cease his country's military invasion of Western companies to pull out of Russia, although Russia has sought to prevent such exits through legislation activities" to destabilize Ukraine. First, OFAC designated two current, pro-Kremlin members of Ukraine's parliament, Taras Kozak and Oleh Voloshyn. Both Kozak and Voloshyn are believed to work on behalf of Russia's intelligence agency and operationalize the Russian Federation's disinformation campaigns. Kozak, for example, controls several news channels in Ukraine and uses his platforms to mock Ukrainian president Volodymyr Zelensky, while Voloshyn reportedly works with Russian actors to undermine Ukrainian officials and advocate on behalf of Russia. Volodymyr Oliynyk, a former Ukrainian official, was designated for allegedly cyber efforts to destabilize Ukraine's access to energy products. Lastly, OFAC designated Vladimir Sivkovich, passing sensitive information about Ukraine's critical infrastructure to Russian officials in support of Russia's former Deputy Secretary of Ukrainian National Security and Defense Council, for attempted influence operations to officially cede Crimea to Russia. Amid intelligence that Russia indeed had aggressive plans against its western it invade Ukraine. neighbor, OFAC made clear that these designations were distinct from any sanctions Russia might face should Throughout the first quarter, rapidly declassified intelligence indicated an imminent Russian invasion, later confirmed on February 24 when Russia launched missile attacks across Ukraine. The international community US, EU, UK, Canada, Japan, and many other countries have imposed a swath of complex and interlocking Ukraine. The unprecedented measures impose coordinated economic restrictions on Russian elites, financial institutions, and sectors of the Russian economy. The moves have already prompted several US and other and reciprocal sanctions. The Russia Harmful Activities program is rapidly evolving, with announcements of new designations or other forms of sanctions being announced often several times a week. This report focuses on those sanctions imposed through early April. We will cover subsequent sanctions in our second quarter Update as well as specific notes highlighting critical intervening developments.

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