Sanctions Round Up First Quarter 2022

Shearman & Sterling LLP

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3 o OFAC imposed full-scale blocking sanctions against Public Joint Stock Company Sberbank of Russia (Sberbank), the largest financial institution in Russia and majority-owned by the Government of the Russian Federation. It is believed that Sberbank holds about one-third of all bank assets in Russia and is the main creditor of the Russian economy. The blocking measures expand existing sanctions against Sberbank, which before only prevented US banks from opening or maintaining correspondent accounts, or processing transactions for Sberbank under Directive 2 of E.O. 14024. OFAC designated forty-two Sberbank subsidiaries for being owned or controlled by, or for having acted or purported to act for or on behalf of, directly or indirectly, Sberbank. o OFAC also imposed full blocking restrictions on Joint Stock Company Alfa-Bank (Alfa-Bank), Russia's largest privately owned financial institution and Russia's fourth-largest financial institution overall. OFAC also designated six subsidiaries of Alfa-Bank and five vessels it owns or controls. • Prominent Family Members: OFAC designated Maria Vladimirovna Vorontsova and Katerina Vladimirovna Tikhonova, identified as daughters of Russian President Vladimir Putin. In addition, OFAC designated Maria Aleksandrovna Lavrova and Yekaterina Sergeyevna Vinokurova, the wife and daughter, respectively, of Russian Foreign Minister Sergey Lavrov. • Russian Elites: OFAC designated additional members of the Security Council of the Russian Federation, chaired by President Putin and composed of members he appoints, a key national security body in Russia that determines and executes Russia's foreign policy, including its unprovoked war of choice against Ukraine. The members were designated pursuant to E.O. 14024 for being or having been a leader, official, senior executive officer, or member of the board of directors of the Government of the Russian Federation. • State-Owned Enterprises: To cut off revenue streams that finance Russia's aggression in Ukraine, OFAC designated two Government of Russia-owned enterprises pursuant to E.O. 14024: Diamond mining company Public Joint Stock Company Alrosa (Alrosa) and warship builder United Shipbuilding Corporation (USC), as wells as all entities owned 50% or more by each entity. Alrosa is the world's largest diamond mining company, believed to generate $4.2 billion in revenue each year. USC, meanwhile, develops and builds nearly all of Russia's warships. Also designated were eight board members of USC.

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