NATIONALLY RECOGNIZED FEDERAL LAWYERS
Russia OFAC Sanctions Program Evolution
|Last Updated on: 21st September 2023, 07:25 pm
The U.S. government has imposed various sanctions against Russia over the years in response to its malign activities around the world. However, sanctions ramped up significantly starting in 2014 after Russia illegally annexed Crimea and started supporting separatists in eastern Ukraine. Since then, sanctions have expanded and evolved as Russia’s aggressive actions have continued.
2014-2016: Sanctions Begin
In March 2014, President Obama issued Executive Order 13660 authorizing sanctions on individuals and entities responsible for violating Ukraine’s sovereignty and territorial integrity. This was done in response to Russia’s annexation of Crimea. Over the next two years, the U.S. designated hundreds of Russian individuals and entities under this and related executive orders.
Some key early sanctions actions included:
- Freezing assets of 7 Russian government officials and 4 Ukrainian separatist leaders
- Imposing sectoral sanctions on Russia’s financial, energy, and defense sectors
- Sanctioning state-owned entities like Gazprom, VTB Bank, and Rostec
- Banning U.S. exports of military and energy technologies to Russia
While impactful, these measures failed to deter Russia’s activities in Ukraine. Fighting continued in eastern Ukraine, with evidence of Russian troops and equipment supporting separatists.
2017-2018: CAATSA and NotPetya
In August 2017, President Trump signed the Countering America’s Adversaries Through Sanctions Act (CAATSA) which imposed mandatory sanctions on Russia. This legislation was passed with strong bipartisan support in response to Russia’s interference in the 2016 U.S. elections, annexation of Crimea, and aggression in Ukraine.
CAATSA expanded sanctions authorities related to Russia’s defense, intelligence, mining, shipping, railway, and financial sectors. It also required sanctions on Russian oligarchs and political figures.
In June 2017, the NotPetya cyberattack was attributed to the Russian military. This destructive malware spread globally, causing billions in damages. In response, OFAC sanctioned several Russian companies and intelligence officers in 2018.
2018-2022: Incremental Expansion
From 2018-2022, the U.S. continued layering on additional sanctions against Russia:
- Sanctioning Russian oligarchs, political elites, and companies over election interference, human rights abuses, and more
- Imposing sanctions for Russia’s poisoning of Sergei Skripal in UK and occupying parts of Georgia/Ukraine
- Targeting enablers of sanctions evasion and Russian intelligence services
- Sanctioning Nord Stream 2 pipeline between Russia and Germany
While impactful, these measures failed to stop Russian aggression. In late 2021, Russia began massing troops on Ukraine’s border in preparation for invasion.
2022: Full-Scale Invasion of Ukraine
On February 24, 2022, Russia launched a full-scale invasion of Ukraine. In response, the U.S. and allies imposed severe economic sanctions, including:
- Cutting off major Russian banks from SWIFT financial system
- Freezing assets of Russian Central Bank and sovereign wealth funds
- Banning U.S. imports of Russian energy, seafood, alcohol, and diamonds
- Imposing full blocking sanctions on large state-owned enterprises
- Sanctioning hundreds more Russian elites, their family members, and proxies
These sweeping measures had immediate and devastating impacts on Russia’s economy and financial system. However, Russia continued its assault on Ukraine.
2022-Present: Choking Off War Machine
Seeing that economic pressure alone was insufficient, the U.S. shifted its sanctions strategy to directly target Russia’s war machine and revenue sources.
Recent key sanctions actions include:
- Banning U.S. exports to Russia of tech products used in defense, aerospace, and maritime industries
- Imposing price caps on Russian oil and petroleum exports
- Sanctioning Russian military supply chains, procurement networks, and intelligence services
- Targeting Russia’s future oil and gas revenue by banning services/tech enabling new exploration and production
- Expanding sectoral sanctions to target Russia’s mining, transportation, electronics, and other key industries
One year into Russia’s invasion of Ukraine, sanctions continue to ratchet up. The U.S. has demonstrated willingness to keep adding pressure until Russia ends its unprovoked war.
Conclusion
U.S. sanctions on Russia have expanded dramatically since 2014 in response to Russia’s escalating aggression. While sanctions failed to deter Russia’s invasion of Ukraine, they are now directly targeting Russia’s war machine and sources of revenue funding the war.
Sanctions will likely continue expanding as long as Russia’s assault on Ukraine continues. However, their ultimate effectiveness depends on coordination and implementation by the U.S., EU, and other allies.