The sanctions implemented by OFAC since February 21, 2022 in response to the conflict in Ukraine have demonstrated a rapid progression in the severity of prohibitions imposed and a clear intent to cause maximum impact on the Russian economy, along with personally targeting President Putin and Russian oligarchs who have benefited from their close relationships with President Putin. Additionally, OFAC has imposed additional sanctions on Belarus for its ties to, and support of, the Russian government. The OFAC sanctions implemented to date can be categorized under four primary themes: (i) Financial Sector sanctions, (ii) Russian Leaders and Oligarchs Designations, (iii) Belarus Sanctions, and (iv) Embargoes, each of which are summarized below:1
Financial sector sanctions
The OFAC sanctions placed on Russian financial institutions (FIs) could be considered the most powerful of the suite of sanctions implemented in response to the Russia-Ukraine conflict to date. OFAC’s response to the conflict commenced on February 21, 2022, following President Putin’s “purported recognition” of areas of the Donetsk and Luhansk regions in Ukraine as independent republics and the deployment of “peacemaking forces” into these regions.2 While the first tranche of sanctions were embargo-focused, subsequent sanctions target the core of the Russian financial system, including the Central Bank of Russia, Ministry of Finance of the Russian Federation, and the National Wealth Fund of the Russian Federation. The prohibition of transactions with these entities through designation via the Non-Specially Designated Nationals (SDN) Menu-Based Sanctions List effectively freezes the assets of these institutions held within the US or by US persons. Additionally, the SDN designation and subsequent blocking of the Russian Direct Investment Fund, which serves as a direct conduit to investment in Russia, further pressures the Russian economy.
OFAC has also taken unprecedented steps in directly targeting Russian financial institutions. OFAC has fully blocked VTB Bank Public Joint Stock Company (VTB Bank), Russia’s second largest financial institution, as well as 20 VTB Bank foreign financial institution subsidiaries. Public Joint Stock Company (PJSC) Sberbank of Russia (Sberbank) was placed on the Correspondent and Payable-Through Account Sanctions (CAPTA) List via Directive 2 under E.O. 14024. The implementation of CAPTA sanctions on Sberbank requires that by March 26, 2022, all US FIs close any Sberbank correspondent or payable-through accounts and reject any future transactions from Sberbank and its foreign financial institutions (FFI) subsidiaries. As a result, Sberbank has effectively been disconnected from US dollar access and the US banking system as a whole.
Additionally, three significant Russian financial institutions—PJSC Bank Financial Corporation Otkritie (Otkritie), Open Joint Stock Company Sovcombank (Sovcombank), and Joint Stock Commercial Bank Novikombank (Novikombank)—are now subject to OFAC blocking sanctions. These three institutions, along with VTB Bank, are also among the seven Russian FIs disconnected from the Society for Worldwide Interbank Financial Telecommunication (SWIFT) payments platform, an action that is further discussed below.
Russian leaders and oligarchs designation
On February 25th, 2022, the US moved to add Russian Federation President Vladimir Putin; Minister of Foreign Affairs, Sergei Lavrov; General Valery Gerasimov, Chief of the General Staff of the Armed Forces of the Russian Federation; and General Sergey Shoygu, Minister of Defense of the Russian Federation, to the SDN List. Both prior to, and following the designation of these Russian leaders, large numbers of Russian oligarchs, their family members, and business interests were added to the SDN list in an effort to sanction not only those who lead, but also those who have profited from their close ties with the Russian government, and more specifically, President Putin.
Concurrently, OFAC designated more than 20 Belarusian individuals and entities as a result of Belarus’ support of the Russian government. OFAC’s sanctions are targeted at Belarus’s defense and financial sectors and further expand on sanctions already implemented by OFAC under E.O.s 13405 and 14038, implemented in response to past actions sanctioned by the US government. Two significant state-owned banks and their 50% owned or controlled subsidiaries, Belarussian Bank of Development and Reconstruction Belinvestbank Joint Stock Company (Belinvestbank) and Bank Dabrabyt Joint-Stock Company (Bank Dabrabyt), were designated as SDNs pursuant to E.O. 14038.
Under E.O. 14065, OFAC implemented sanctions that prohibit new investment3 in Donetsk and Luhansk (referred to by Russia as the Donetsk People’s Republic (DNR) and Luhansk People’s Republic (LNR) regions of Ukraine) (the Covered Regions). Sanctions relative to the Covered Regions also prohibit the direct or indirect import/export of goods, services, or technology, and the approval, financing, facilitation, or guarantee by a U.S person of a transaction by a foreign person where the transaction by that foreign person would be prohibited if performed by a US person or within the US. Blocking sanctions were also placed on the following: (i) property of leaders, officials, senior executive officers, and /or members of the board of directors of an entity operating in the Covered Regions; (ii) entities that operate in the Covered Regions and their owners/controllers or their representatives; (iii) contributions or receipt of contributions, or provision or receipt of any funds, goods, or services subject to blocking; (iv) and those who have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of any person whose property and interests in property pursuant to the E.O.
Additionally, on March 1, 2022, the “Russian Harmful Foreign Activities Sanctions Regulations” (the Regulations) were published in the Federal Register. The Regulations were enacted to implement E.O. 14024. The regulations published are expected to be expanded further to include a more comprehensive set of regulations, which per the Federal Register may include additional interpretive guidance and definitions, general licenses issued by OFAC, and other regulatory provisions.
 Specific OFAC sanctions and Directives issued to date are subject to general licenses that provide authorization for specific transactions associated with designated individuals, entities, and jurisdictions, as described therein.
 See Executive Order 14065 of February 21, 2022, Blocking Property of Certain Persons and Prohibiting Certain Transactions with Respect to Continued Russian Efforts to Undermine the Sovereignty and Territorial Integrity of Ukraine.
 EO 14065 sets forth the following language around investment activity: “(a) The following [is] prohibited: (i) new investment in the so-called DNR or LNR regions of Ukraine or such other regions of Ukraine as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State (collectively, the “Covered Regions”), by a United States person, wherever located.”