As the Russia-Ukraine conflict escalates, the U.S. Government has started to implement new sanctions on Russian entities on top of the ones that already existed. On February 21, 2022, the Executive Order on Blocking Property of Certain Persons and Prohibiting Certain Transactions With Respect to Continued Russian Efforts to Undermine the Sovereignty and Territorial Integrity of Ukraine (the “Order”) was issued.1 The Order seeks to cut Russia off from Western financing by prohibiting Western individuals from investing, trading, or financing in the separatist regions. Companies should be prepared to address the current and future sanctions against Russia—and others—to help avoid operational and supply chain disruptions.

Specifically, some of the sanctions in the Order target Russian financial institutions, including Vnesheconombank, Promsvyazbank, and their subsidiaries. This portion of the Order seeks to eliminate Russia’s primary means of raising funds by preventing U.S. entities from buying Russian sovereign debt. In addition, the U.S. Department of Treasury updated the Office of Foreign Asset Control’s Specially Designated Nationals list to include designated individuals who operate or have operated in the financial services sector of the Russian economy. It is expected that additional financial institutions – in and out of Russia – will be added to this list and may directly impact several industries globally, primarily in regard to energy.

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