The Russian Federation and the United States continue to clash over the proposed annexation of Crimea from Ukraine, with the United States adding 20 Russian officials and related persons to its list of sanctioned persons. Some of the persons recently added to the United States' SDN List were recently sanctioned by the EU, as we have noted earlier this week. Others appear to be novel additions under either the EU or United States' sanctions lists, and include Russian officials, lawmakers, and persons within Vladimir Putin's inner circle. For its part, the EU added 12 persons to its list of those subject to the initial travel ban and asset freeze. These new additions have caused a flurry of activity in the international business community as people scramble to guard their investments.

Specifically, the new sanctions have immediate consequences in the financial services and energy industries. For example, the United States' sanctions target Russia's Bank Rossiya, prohibiting U.S. firms and individuals from doing business with the $10 billion bank. As a result, Visa and MasterCard have stopped providing services for Bank Rossiya's clients. In addition, the sanctions target the Rotenberg brothers, two Russian billionaires who have been acquiring subsidiaries of Gazprom, Russia's state-run energy giant. Gennady Timchenko, who recently sold his 45 percent stake in Gunvor Group Ltd., was also targeted. Timchenko sold his shares to his partner, Torbjorn Törnqvist, in anticipation of the repercussions these sanctions might have on billions of dollars of energy contracts. These developments raise questions about the probability of sanctions against Gazprom itself and the risks of investing in Russia.

Below are the specific names added to the United States' and EU sanctions lists.

Persons Added to the United States' Sanctions List

The following persons (and one entity) were recently added to the OFAC's Specially Designated Nationals List:

  • BUSHMIN, Evgeni Viktorovich (a.k.a. BUSHMIN, Evgeny; a.k.a. BUSHMIN, Yevgeny); DOB 10 Oct 1958; POB Lopatino, Sergachiisky Region, Russia; Deputy Speaker of the Federation Council of the Russian Federation; Chairman of the Council of the Federation Budget and Financial Markets Committee (individual) [UKRAINE2].
  • DZHABAROV, Vladimir Michailovich; DOB 29 Sep 1952; First Deputy Chairman of the International Affairs Committee of the Federation Council of the Russian Federation (individual) [UKRAINE2].
  • FURSENKO, Andrei Alexandrovich (a.k.a. FURSENKO, Andrei; a.k.a. FURSENKO, Andrey); DOB 17 Jul 1949; POB St. Petersburg, Russia; Aide to the President of the Russian Federation (individual) [UKRAINE2].
  • GROMOV, Alexei; DOB 1960; POB Zagorsk (Sergiev, Posad), Moscow Region, Russia; First Deputy Chief of Staff of the Presidential Executive Office; First Deputy Head of Presidential Administration; First Deputy Presidential Chief of Staff (individual) [UKRAINE2].
  • IVANOV, Sergei (a.k.a. IVANOV, Sergey); DOB 31 Jan 1953; POB St. Petersburg, Russia; Chief of Staff of the Presidential Executive Office (individual) [UKRAINE2].
  • IVANOV, Victor Petrovich (a.k.a. IVANOV, Viktor); DOB 12 May 1950; alt. DOB 1952; POB Novgorod, Russia (individual) [UKRAINE2].
  • KOZHIN, Vladimir Igorevich; DOB 28 Feb 1959; POB Troitsk, Chelyabinsk Oblast, Russia (individual) [UKRAINE2].
  • KOVALCHUK, Yuri Valentinovich (a.k.a. KOVALCHUK, Yury Valentinovich); DOB 25 Jul 1951; POB Saint Petersburg, Russia (individual) [UKRAINE2].
  • MIRONOV, Sergei Mikhailovich (a.k.a. MIRONOV, Sergei); DOB 14 Feb 1953; POB Pushkin, Saint Petersburg, Russia; Member of the Council of the State Duma; Leader of A Just Russia Party; Member of the State Duma Committee on Housing Policy and Housing and Communal Services (individual) [UKRAINE2].
  • NARYSHKIN, Sergey Yevgenyevich (a.k.a. NARYSHKIN, Sergei); DOB 27 Oct 1954; POB Saint Petersburg, Russia (individual) [UKRAINE2].
  • OZEROV, Viktor Alekseevich (a.k.a. OZEROV, Viktor Alexeyevich); DOB 05 Jan 1958; POB Abakan, Khakassia, Russia; Chairman of the Security and Defense Federation Council of the Russian Federation (individual) [UKRAINE2].
  • PANTELEEV, Oleg Evgenevich (a.k.a. PANTELEEV, Oleg); DOB 21 Jul 1952; POB Zhitnikovskoe, Kurgan Region, Russia; First Deputy Chairman of the Committee on Parliamentary Issues (individual) [UKRAINE2].
  • ROTENBERG, Arkady; DOB 15 Dec 1951; POB St. Petersburg, Russia (individual) [UKRAINE2].
  • ROTENBERG, Boris; DOB 03 Jan 1957; POB St. Petersburg, Russia (individual) [UKRAINE2].
  • RYZHKOV, Nikolai Ivanovich (a.k.a. RYZHKOV, Nikolai); DOB 28 Sep 1929; POB Duleevka, Donetsk Region, Ukraine; Senator in the Russian Upper House of Parliament; Member of the Committee for Federal Issues, Regional Politics and the North of the Federation Council of the Russian Federation (individual) [UKRAINE2].
  • SERGUN, Igor Dmitrievich; DOB 28 Mar 1957; Lieutenant General; Chief of the Main Directorate of the General Staff (GRU); Deputy Chief of the General Staff (individual) [UKRAINE2].
  • TIMCHENKO, Gennady (a.k.a. TIMCHENKO, Gennadiy Nikolayevich; a.k.a. TIMCHENKO, Gennady Nikolayevich; a.k.a. TIMTCHENKO, Guennadi), Geneva, Switzerland; DOB 09 Nov 1952; POB Leninakan, Armenia; alt. POB Gyumri, Armenia; nationality Finland; alt. nationality Russia; alt. nationality Armenia (individual) [UKRAINE2].
  • TOTOONOV, Aleksandr Borisovich (a.k.a. TOTOONOV, Alexander; a.k.a. TOTOONOV, Alexander B.); DOB 03 Mar 1957; POB Ordzhonikidze, North Ossetia, Russia; alt. POB Vladikavkaz, North Ossetia, Russia; Member of the Committee on Culture, Science, and Information, Federation Council of the Russian Federation (individual) [UKRAINE2].
  • YAKUNIN, Vladimir; DOB 30 Jun 1948; POB Vladimir Oblast, Russia (individual) [UKRAINE2].
  • ZHELEZNYAK, Sergei Vladimirovich (a.k.a. ZHELEZNYAK, Sergei; a.k.a. ZHELEZNYAK, Sergey); DOB 30 Jul 1970; POB Saint Petersburg, Russia; Deputy Speaker of the State Duma of the Russian Federation (individual) [UKRAINE2].
  • BANK ROSSIYA (f.k.a. AKTSIONERNY BANK RUSSIAN FEDERATION), 2 Liter A Pl. Rastrelli, Saint Petersburg 191124, Russia; SWIFT/BIC ROSY RU 2P; Website www.abr.ru; Email Address bank@abr.ru [UKRAINE2].

Persons Added to the European Union Sanctions List

The EU have recently added 12 persons (PDF of EU Council Implementing Regulation) to those noted in our earlier post who were the subject of the initial travel ban and asset freeze. Those twelve persons are now subject to a travel ban and asset freeze, and they are:

  • Rogozin, Dmitry Olegovich; DOB 21 December 1963; POB Moscow; Deputy Prime Minister of the Russian Federation
  • Glazyev, Sergey; DOB 1 January 1961; POB Zaporozhye (Ukrainian SSR); Adviser to the President of the Russian Federation
  • Matviyenko, Valentina Ivanova; DOB 7 April 1949; POB Shepetovka, Khmelnitskyi oblast (Ukrainian SSR); Speaker of the Federation Council
  • Naryshkin, Sergei Evgenevich; DOB 27 October 1954; POB St. Petersberg; Speaker of the State Duma
  • Kiselyov, Dmitry Konstantinovich; DOB 26 April 1954; POB not supplied; Head of the Russian Federal State news agency Rossiya Segodnya
  • Nosatov, Alexander; DOB 27 March 1963; POB Sevastopol (Ukrainian SSR); Deputy Commander of the Black Sea Fleet
  • Kulikov, Valery Vladimirovich; DOB 1 September 1956; POB Zaporozhye (Ukrainian SSR); Deputy Commander of the Black Sea Fleet
  • Surkov, Vladislav Yurievich; DOB 21 September 1964; POB Solntsevo, Lipetsk; Aide to the President of the Russian Federation
  • Malyshev, Mikkhail; DOB not supplied; POB not supplied; Chair of the Crimea Electoral Commission
  • Medvedev, Valery; DOB not supplied; POB not supplied; Chair of Sevastopol Electoral Commission
  • Lt. Gen. Igor Turchenyuk; DOB not supplied; POB not supplied; Commander of Russian forces in Crimea
  • Mizulina, Elena Borisovna; DOB not supplied; POB not supplied; Deputy in the State Duma

The situation is reaching a point where further sanctions may have negative consequences for Western companies. Anyone with foreign investments or energy contracts would be well-advised to keep a watchful eye on these developments. Such caution should extend to the international business community as well, given the increasingly interconnected nature of our financial and energy markets.

This article is presented for informational purposes only and is not intended to constitute legal advice.