
Updated August 29, 2019
U.S. Sanctions on Russia: An Overview
The United States imposes sanctions on Russian persons
first is EO 13694, as amended by EO 13757 (and codified
(individuals, entities, and vessels) in response to Russia’s
by CRIEEA). This executive order targets those who
invasion of Ukraine, election interference, other malicious
engage in cyberattacks (1) against critical infrastructure, (2)
cyber-enabled activities, human rights abuses, use of a
for financial or commercial gain, (3) to significantly disrupt
chemical weapon, weapons proliferation, illicit trade with
the availability of a computer or network, or (4) to interfere
North Korea, and support to Syria and Venezuela.
with U.S. election processes and institutions.
Sanctions against Russian persons may include blocking of
The second authority is CRIEEA, Section 224, which
assets subject to U.S. jurisdiction; limits on access to the
requires the President to impose sanctions in response to a
U.S. financial system, including limiting or prohibiting
range of activities conducted on behalf of the Russian
transactions involving U.S. individuals and businesses; and
government that undermine “cybersecurity against any
denial of entry into the United States. The United States
person, including a democratic institution, or government.”
also tightly controls exports to Russia’s energy and defense
sectors. For more, see CRS Report R45415, U.S. Sanctions
Under these authorities, the United States has designated
on Russia.
for election-related malicious cyber activities at least 40
Russian persons, including Russia’s leading intelligence
Invasion of Ukraine
agency (FSB) and military intelligence (GRU). Many of
Most U.S. designations of Russian persons subject to
these designees have been indicted by the Department of
sanctions are in response to Russia’s 2014 invasion and
Justice’s Special Counsel’s Office for crimes related to
occupation of Ukraine’s Crimea region and areas of eastern
election interference.
Ukraine, as well as its maritime aggression near the Sea of
Azov. To date, the United States has imposed Ukraine-
Six of these persons, and at least another 20, also have been
related sanctions on more than 665 persons.
designated for other malicious cyber-related activities,
including the 2017 “NotPetya” global ransomware attack
The basis for most Ukraine-related sanctions is a series of
and cyberattacks against the World Anti-Doping Agency
executive orders (EOs 13660, 13661, 13662, and 13685)
(WADA) and the Organization for the Prohibition of
that were issued in 2014 and codified by the Countering
Chemical Weapons (OPCW).
Russian Influence in Europe and Eurasia Act of 2017
(CRIEEA; P.L. 115-44, Title II; 22 U.S.C. 9501 et seq.).
Also in response to malicious cyber-enabled activities,
The EOs provide for sanctions against those the President
CRIEEA, at Section 231, requires the President to impose
determines have undermined Ukraine’s security and
sanctions on any person who engages in significant
stability; misappropriated Ukrainian state assets; or
transactions with the Russian defense or intelligence
conducted business, trade, or investment in occupied
sectors. In September 2018, the Administration designated
Crimea. They also provide for sanctions against Russian
the Equipment Development Department of China’s Central
government officials and those who offer them support,
Military Commission, as well as its director, for taking
persons who operate in the Russian arms sector, and
delivery of 10 combat aircraft and surface-to-air missile
persons who operate in key sectors of the Russian economy.
system-related equipment. Turkey also has begun to take
possession of surface-to-air missile systems from Russia.
Sectoral sanctions, in particular, apply to specific entities in
As of August 2019, the Trump Administration has not
Russia’s financial, energy, and defense sectors. U.S.
imposed Section 231 sanctions in response.
persons are restricted from engaging in specific transactions
with these entities, which are identified as subject to one of
Human Rights Abuse and Corruption
four directives. Restrictions apply to new equity investment
The Sergei Magnitsky Rule of Law Accountability Act of
and financing for identified entities in Russia’s financial
2012 (P.L. 112-208, Title IV; 22 U.S.C. 5811 note) requires
sector, and new financing for identified entities in Russia’s
the President to impose sanctions on persons he identifies
energy and defense sectors. Sectoral sanctions also prohibit
as having been involved in a “criminal conspiracy”
U.S. trade related to the development of Russian deepwater,
uncovered by Russian lawyer Sergei Magnitsky or his
Arctic offshore, or shale projects that have the potential to
subsequent imprisonment and death. The act also requires
produce oil and, as amended by CRIEEA, such projects
the President to impose sanctions on those he finds have
worldwide in which identified entities have an ownership
committed human rights abuses against individuals who are
interest of at least 33% or a majority of voting interests.
fighting to expose the illegal activity of Russian
government officials or seeking internationally recognized
Malicious Cyber-Enabled Activities
human rights and freedoms.
Sanctions imposed on Russian persons in response to
malicious cyber activities are based on two authorities. The
https://crsreports.congress.gov
U.S. Sanctions on Russia: An Overview
Fifty-five persons are designated under the Sergei
of refined petroleum products,” under EO 13722 and EO
Magnitsky Act. Other Russian persons have been
13810. In June 2019, the Administration designated a
designated under the Global Magnitsky Human Rights
Russian institution for providing financial services to North
Accountability Act (P.L. 114-328, Title XII, Subtitle F; 22
Korea’s primary foreign exchange bank under EO 13382.
U.S.C. 2656 note) and EO 13818, which address human
rights abuses and corruption more broadly.
Syria- and Venezuela-Related Sanctions
The Trump Administration designated Rosoboronexport
The Support for the Sovereignty, Integrity, Democracy, and
and an associated bank for their support to the Syrian
Economic Stability of Ukraine Act of 2014, as amended by
government under EO 13582 in 2018, adding to the Obama
§228 of CRIEEA (SSIDES; P.L. 113-95; 22 U.S.C. 8901 et
Administration’s designation of two Russian banks and
seq.), requires sanctions on those responsible for serious
related individuals under the same EO.
human rights abuses in “any territory forcibly occupied or
otherwise controlled” by Russia. In November 2018, the
In March 2019, the Administration designated a bank that is
Administration designated three persons for human rights
jointly owned by Russian and Venezuelan state-owned
abuses in Russian-occupied regions of Ukraine.
companies under EO 13850 for providing support to
Venezuela’s state-owned oil company, Petroleos de
Use of a Chemical Weapon
Venezuela, S.A. (PdVSA), which the Administration
In August 2018, the United States determined that Russia
designated in January 2019 to curb the availability of
used a chemical weapon in contravention of international
resources to the regime of Nicolas Maduro.
law in relation to the March 2018 nerve agent attack on
British citizen Sergei Skripal, a former Russian military
Other Sanctions and Restrictions
intelligence officer once imprisoned in Russia for allegedly
In addition to imposing export-licensing restrictions on
working as a UK double agent, and his daughter. This
Russian persons in response to Russia’s invasion of
finding triggered the Chemical and Biological Weapons
Ukraine, the Department of Commerce imposes such
Control and Warfare Elimination Act of 1991 (CBW Act,
restrictions on other Russian persons that engage in
P.L. 102-182, Title III; 22 U.S.C. 5601 et seq.).
activities considered contrary to U.S. national security
and/or foreign policy interests. In December 2017,
Pursuant to the CBW Act, the President has imposed two
Commerce imposed restrictions on two entities for
rounds of sanctions on Russia. As of August 2019, these
producing a ground-launched cruise missile system and
include prohibitions on exporting many controlled goods
associated launcher in violation of the Intermediate-Range
and services, lending non-ruble-denominated funds to the
Nuclear Forces Treaty.
Russian government, and participating in the primary
market for non-ruble-denominated sovereign bonds. In
As in past years, FY2019 appropriations for national
addition, the Trump Administration has designated two
defense, energy, and foreign operations programs restrict
GRU officers for their involvement in the nerve agent
assistance to the Russian government. The State
attack. For more, see CRS In Focus IF10962, Russia, the
Department’s 2019 Trafficking in Persons Report identifies
Skripal Poisoning, and U.S. Sanctions.
Russia as a Tier 3 nation that fails to meet minimum
standards for the elimination of human trafficking. This
Weapons Proliferation
designation requires limits on aid and cultural exchanges.
Pursuant to the Iran, North Korea, and Syria
Nonproliferation Act, as amended (INKSNA, P.L. 106-178;
Around three dozen Russian persons currently are
50 U.S.C. 1701 note), state-owned arms exporter
designated under global sanctions regimes related to
Rosoboronexport and some other Russian defense entities
terrorism and transnational crime.
are denied most U.S. government procurement contracts,
export licenses, and trade in U.S. Munitions List-controlled
Other Available Sanctions
items. In April 2018, the Trump Administration designated
As of August 2019, the Administration has not made
Rosoboronexport for providing support to the Syrian
designations under other new CRIEEA authorities related to
government. In addition, Rosoboronexport is subject to
pipeline development, privatization deals, or support to
Ukraine-related sectoral sanctions and other restrictions that
Syria (§§232-234). The Administration also has not made
prohibit U.S. government contracts and other transactions.
other designations under SSIDES or the Ukraine Freedom
Support Act of 2014 (UFSA; P.L. 113-272; 22 U.S.C. 8921
North Korea Sanctions Violations
et seq.; as amended by CRIEEA, §§225-228) related to
The Trump Administration has designated at least 22
weapons transfers abroad, certain oil projects, corruption,
Russia-related persons for evading sanctions that restrict
and secondary sanctions against foreign persons that
trade and financial transactions with North Korea. In 2017,
facilitate significant transactions or sanctions evasion for
the Administration designated seven persons under EO
Russia-related designees. Some Members of Congress have
13722 for trade in petroleum with North Korea. The
called on the President to make more designations based on
Administration designated another four persons under EOs
CRIEEA’s mandatory sanctions provisions.
12938 and 13382 for providing supplies and procuring
metals to a North Korean company subject to sanctions for
Dianne E. Rennack, Specialist in Foreign Policy
its weapons of mass destruction programs. In 2018, the
Legislation
Administration designated 10 persons for facilitating trade
Cory Welt, Analyst in European Affairs
with North Korea, including through “ship-to-ship transfer
https://crsreports.congress.gov
U.S. Sanctions on Russia: An Overview
IF10779
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