Russia - Country Commercial Guide
Sanctions Framework
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The USG has escalated sanctions on Russia since 2014 in response to Russia’s incursions into and invasion of Ukraine, cyber-attacks, malign influence, use of chemical weapons, and election meddling.

Most economic sanctions are imposed using authority delegated to the President in the International Emergency Economic Powers Act (IEEPA) and the National Emergencies Act (NEA). Under IEEPA, the President generally issues an executive order declaring a national emergency under the NEA; sets out the legal bases upon which the Secretary of the Treasury or other officials (Secretary of State, etc.) may designate specific foreign persons who will be subject to the sanctions; and establishes the types of transactions or other prohibitions that shall apply to designated persons.

Please see the section “U.S. Export Controls” for more detailed information on the Export Administration Regulations (EAR) and the Bureau of Industry and Security (BIS).

The State Department develops and implements foreign policy-related sanctions adopted to counter threats to national security posed by particular activities and countries. State also builds international diplomatic support for implementation of economic sanctions, provides foreign policy guidance to the Department of Treasury and Commerce on sanctions implementation, and works with Congress to draft legislation that advances U.S. foreign policy goals in these areas. The Department of the Treasury’s Office of Foreign Assets Control (OFAC) plays a primary role in administering and enforcing many U.S. economic sanctions programs. In coordination with the Department of State, OFAC issues licenses where appropriate for a variety of goods, services and transactions. The Department of Commerce’s Bureau of Industry and Security (BIS) is responsible for developing export control policies and issuing export licenses for particular goods/end users/destinations as appropriate in consultation with the Departments of State, Defense, and Energy.

Sanctions Before the February 2022 Russian Invasion of Ukraine

Most U.S. sanctions imposed before the 2022 Russian invasion of Ukraine were in response to Russia’s 2014 invasion and annexation of Ukraine’s Crimea region and Russia’s support for conflict in eastern Ukraine.  The basis for these Ukraine-related sanctions is a series of Executive Orders (EOs 13660, 13661, 13662, and 13685) that were issued in 2014 and codified by the Countering Russian Influence in Europe and Eurasia Act of 2017 (CRIEEA; P.L. 115-44, Title II; 22 U.S.C. 9501 et seq.), a part of the broader “Countering America’s Adversaries Through Sanctions Act” (CAATSA). These Executive Orders provided for sanctions against those that the President determined to have undermined Ukraine’s security and stability, misappropriated Ukrainian state assets, or conducted business, trade, or investment in occupied Crimea. They also provided for sanctions against any Russian government officials and those who offer them support, and persons who operate in the Russian arms sector or other key sectors of the Russian economy.

Sectoral sanctions apply to specific entities in Russia’s financial, energy, and defense sectors. U.S. persons are restricted from engaging in specific transactions with these designated entities.  Restrictions applied to new equity investment and financing for entities in Russia’s financial sector; and new financing for identified entities in Russia’s energy and defense sectors. Sectoral sanctions also prohibit U.S. trade related to the development of Russian deep-water, Arctic offshore, or shale projects that have the potential to produce oil and, as amended by CRIEEA, such projects worldwide in which those entities have an ownership interest of at least 33% or a majority of voting interests.

The United States revised CAATSA Section 232 guidance in July 2020, opening up the possibility of sanctions on entities facilitating the completion of the Nord Stream 2 pipeline. Several Russian entities and ships involved with the construction and pipelaying of Nord Stream 2 have been sanctioned, and the U.S. Congress considered a number of proposals related to Nord Stream 2 with potential sanctions implications for Russian entities and their partners on the Nord Stream 2 and Turkstream projects. 

In addition to Ukraine-related sanctions, the United States maintains certain sanctions in response to malicious cyber activities, under EO 13694, as amended by EO 13757 (and codified by CRIEEA). These measures target Russian individuals and entities that have engaged in cyberattacks against critical infrastructure, for financial or commercial gain, to significantly disrupt availability of computers or networks, or for the purpose of interfering with U.S. election processes and institutions.  CRIEEA, at Section 224, enlarged the scope of cyber-related activities subject to sanctions to include a range of activities conducted on behalf of the Russian government that undermine “cybersecurity against any person, including a democratic institution, or government.”

The Sergei Magnitsky Rule of Law Accountability Act of 2012 (P.L. 112-208, Title IV; 22 U.S.C. 5811 note) requires the President to impose sanctions on persons he identifies (U.S. Sanctions on Russia: An Overview | 7-5700) as having been involved in either a “criminal conspiracy” uncovered by Russian lawyer Sergei Magnitsky or his subsequent imprisonment and death. The act also requires the President to impose sanctions on those he finds have committed human rights abuses against individuals who are fighting to expose the illegal activity of Russian government officials or seeking internationally recognized human rights and freedoms.

The Support for the Sovereignty, Integrity, Democracy, and Economic Stability of Ukraine Act of 2014, as amended (SSIDES; P.L. 113-95; 22 U.S.C. 8901 et seq.), requires sanctions on those responsible for serious human rights abuses in “any territory forcibly occupied or otherwise controlled” by the Russian government. In November 2018, the Administration designated three persons for human rights abuses in Russian-occupied regions of Ukraine.

Use of a Chemical Weapon: In August 2018, the United States determined that Russia used a chemical weapon in violation of international law in the March 2018 nerve agent attack on a British citizen and his daughter. This finding triggered the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (CBW Act, P.L. 102-182, Title III; 22 U.S.C. 5601 et seq.). The CBW Act requires the President to terminate most foreign aid, arms sales, export licenses for controlled goods and services, and government-backed financial assistance. The second round of CBW sanctions announced in August 2019, prohibited U.S. banks’ participation in the primary market for non-ruble denominated bonds issued by Russia and lending to the Russian government/sovereign; outlined U.S. opposition to the extension of any loan or financial or technical assistance to Russia by international financial institutions; and tightened restrictions on the export of certain products subject to restrictions administered by the Department of Commerce’s Bureau of Industry and Security.

The United States also determined that Russia used a chemical weapon in an August 2020 attack on Alexei Navalny, again triggering the CBW Act and requiring the President to terminate most foreign aid, arms sales, export licenses for controlled goods and services, and government-backed financial assistance. The second round of CBW sanctions in response to the Navalny poisoning was announced in August 2021, as required by the law.

Weapons Proliferation: A number of Russian defense-industry entities, including state-owned arms exporter Rosoboronexport, are denied most U.S. government contracts, export licenses, and trade in U.S. Munitions List-controlled items Pursuant to the Iran, North Korea, and Syria Nonproliferation Act, as amended (INKSNA, P.L. 106-178; 50 U.S.C. 1701 note).  Other Russian entities are subject to sanctions under other legal authorities for providing certain goods or facilitating trade with North Korea or for their support to the Syrian government.

Sanctions In Response to the February 2022 Russian Invasion of Ukraine

Russia launched an unprovoked invasion of Ukraine on February 24, 2022, three days after officially recognizing the independence of the breakaway Donetsk and Luhansk People’s Republics. At the time of CCG publication (summer 2022) Russia continued its attack on Ukraine, occupying territory in eastern and southern Ukraine.

In response to Russia’s aggression, the United States led a coordinated and comprehensive effort to expand the scope and intensity of economic sanctions, political sanctions, and export controls, working with an unprecedented coalition of partners and allies that includes the European Union (EU), the United Kingdom (UK), Canada, Australia, Japan, South Korea, and a continually expanding list of countries who are working to deny Russia the technology and funding necessary to continue its aggression against Ukraine. 

A short timeline of major U.S. economic sanctions imposed on Russia from February through May 2022 includes:

  • On February 22, the Treasury Department announced the first U.S. tranche of sanctions in lockstep with allies and partners. Blocking sanctions against major Russian banks (VEB and Promsvyazbank) were announced, as were additional restrictions on Russian sovereign debt, and sanctions on Kremlin-connected elites.
  • On February 24, the Treasury Department announced further measures on Russia, including the imposition of sanctions on more Russian banks, the expansion of Russia-related debt and equity restrictions to major state-owned enterprises (SOEs) and private companies, and imposition of blocking sanctions on more Kremlin-connected political and business elites.
  • On March 24, Treasury imposed sanctions on dozens of Russian defense companies, 328 members of the Russian State Duma, and the head of Russia’s largest financial institution – Sber (Sberbank).
  • On March 31, Treasury announced additional sanctions designations against the Russian technology sector to prevent evasion of multilateral sanctions and the procurement of critical Western technology.
  • On April 6, Treasury imposed full blocking sanctions on Sberbank, Russia’s largest state-owned bank, and Alfa-Bank, Russia’s largest private bank. Treasury also targeted family members of President Vladimir Putin and Foreign Minister Sergey Lavrov, and Russian Security Council members.
  • On April 7, Treasury imposed full blocking sanctions on Alrosa, a Russian state-owned enterprise (SOE) and the world’s largest diamond mining company, responsible for 90 percent of Russia’s diamond mining capacity. The Department of State also re-designated the United Shipbuilding Corporation (USC).
  • On April 20, Treasury made further designations of entities and individuals involved in attempts to evade sanctions, including a virtual currency mining company.
  • On May 8, Treasury announced new Specially Designated National (SDN) designations of leading Russian financial sector executives, defense and media entities, and prohibited provision of U.S. accounting, trust and corporate formation, and management consulting services to any person located in the Russian Federation.
  • On June 2, Treasury announced new Specially Designated National (SDN) designations of Russian government officials, Putin associates, and representatives of related financial support networks.
  • On June 28, Treasury announced new Specially Designated National (SDN) designations of 70 Russian entities critical to the Russian Federation’s defense industrial base, including State Corporation Rostec, and announced a prohibition on the importation into the United States of gold of Russian Federation origin.

Other major USG actions taken in response to Russia’s invasion of Ukraine affecting trade at the time of CCG publication include:

  • On March 1, the U.S. Department of Transportation and its Federal Aviation Administration issued orders blocking Russian aircraft and airlines from entering and using all domestic U.S. airspace.
  • On March 8, President Biden signed an Executive Order that bans the importation into the United States of Russian crude oil and certain petroleum products (the United States imported almost 700,000 barrels/day of Russian oil last year), liquefied natural gas, coal, and new U.S. investment in Russia’s energy sector.
  • On March 11, President Biden (together with G7 Leaders) announced new economic actions. These included steps to revoke Permanent Normal Trade Relations for Russia, a ban on the export of luxury goods to Russia, a prohibition on the import of goods from several signature sectors of Russia’s economy – including seafood, spirits/vodka, and non-industrial diamonds – representing over $1 billion of Russian imports, and more blocking sanctions on Russian political and business elites.
  • On April 6, the White House announced a prohibition on new investment in the Russian Federation, and provision of certain services in Russia.
  • On April 21, the White House announced a prohibition on Russian-affiliated vessels (flagged, owned, or operated) from entering U.S. ports.

In addition, the Bureau of Industry & Security (BIS) at the Commerce Department announced expanded export controls on February 24, severely restricting Russia’s access to many technologies and items needed to sustain its aggressive military capabilities. These controls primarily target Russia’s defense, aerospace, and maritime sectors and include semiconductors, computers, telecommunications, information security equipment, lasers, and sensors. BIS has taken additional actions since February 24. Please see the section “U.S. Export Controls” for more detail on BIS and on these actions.

This list of economic sanctions and other USG actions here represents a summary of measures taken through late May 2022. Companies should be aware that the imposition of additional sanctions, export controls, and USG actions on other Russian entities and individuals after May 2022 is possible.  See more under U.S. Export Controls article: