Significant Update of SDN List and Tightening US Sanctions
On June 12, OFAC issued a significant update to the SDN list and tightened the US sanctions regulation. It targets the Russian financial infrastructure and Russia’s operations with third countries. The SDN list was also supplemented by the US State Department.
  1. The Moscow Exchange is added to the SDN list, resulting in the cessation of dollar and euro trading from June 13. Also added to the list are the Moscow Exchange subsidiaries NCC and NSD.

OFAC issued General Licenses 99 and 100 authorizing transactions necessary to wind-down the relations with the Moscow Exchange, NCC and NSD until August 13, 2024.

  1. Executive Order 14071 is supplemented to prohibit the provision of IT consultancy and design services, IT support services, and cloud-based services for enterprise management, design, and manufacturing software to Russian entities. Direct or indirect provision of such services to any person located in the Russian Federation is now prohibited.

  2. The definition of the military-industrial base for the support of which foreign financial institutions risk being sanctioned is expanded to include anyone designated pursuant to Executive Order 14024. This Executive Order has been the basis for the vast majority of US sanctions since 2022, therefore, this restriction will affect virtually all designated individuals and entities in the Russian Federation.

  1. New entities are added to the SDN list, including the Russian National Reinsurance Company, as well as a number of companies that OFAC believes are involved in sanctions evasion, the defense sector of the Russian economy, and liquefied natural gas projects. The list includes a large number of companies from China, UAE, Turkey, Hong Kong, Belarus and Kazakhstan.

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