Sanctions 18 Apr, 2018 Russia: Increased sanctions - Update Download PDF On 6 th April OFAC and the State Department added 7 Russian oligarchs to the list of SDNs together with 12 companies which they control, and 17 senior Russian officials. While US persons are prohibited from engaging in any transactions with these designated entities or individuals there are also potential repercussions in that foreign individuals could be subject to US sanctions if they facilitate significant transactions for or on behalf of the designated entities or individuals. The recently designated companies include: AGROHOLDING KUBAN BASIC ELEMENT LIMITED B-FINANCE LTD. EN+ GROUP GAZ GROUP GAZPROM BURENIE, OOO JSC EUROSIBENERGO LADODA MENEDZHMENT, OOO NPV ENGINEERING OPEN JOINT STOCK COMPANY PLC RENOVA GROUP RUSSIAN MACHINES UNITED COMPANY RUSAL PLC US Banks cannot process any payments to or from the above entities, or the newly listed individuals. The Club's US attorneys Freehill Hogan & Mahar advise the impact on foreign nationals as follows: While the U.S. SDN List typically does not have extraterritorial effect, in this instance foreign persons are potentially exposed to U.S. sanctions because of the amendment of Section 10 of SSIDES by Section 228 of CAATSA. Under amended Section 10, it is now mandatory that sanctions be imposed on any foreign person who is determined to have knowingly facilitated a significant transaction for or on behalf of any person subject to U.S. sanctions against Russia, which would include all of those individuals and entities designated on April 6th. OFAC FAQs advise that, as used in Section 10, “persons subject to sanctions imposed by the United States with respect to the Russian Federation”, includes persons listed on either the SDN List or the Sectoral Sanctions Identification List. Section 10 also extends to any child, spouse, parent or sibling of any designated individual. Obviously, of critical importance is what is meant by “facilitates” and “sig