U.S. Sanctions on Russia

U.S. Sanctions on Russia
January 18, 2022
In early 2022, Congress, the Biden Administration, and other stakeholders are considering the
prospect of new sanctions on Russia. In response to a Russian military buildup near and in
Cory Welt, Coordinator
Ukraine, the United States and European allies have said they would impose additional sanctions
Specialist in Russian and
in the event of further Russian aggression against Ukraine. Such sanctions could include greater
European Affairs
restrictions on transactions with Russian financial institutions and U.S. technology exports, as

well as the suspension of Russia’s pending Nord Stream 2 natural gas pipeline project. Further
additional sanctions, including on Russia’s energy sector and secondary market transactions in
Kristin Archick
Specialist in European
Russian sovereign debt, also may be under consideration.
Affairs

Sanctions are a central element of U.S. policy to counter and deter malign Russian activities. The
United States maintains sanctions on Russia mainly in response to Russia’s invasion of Ukraine
Rebecca M. Nelson
starting in 2014, to reverse and deter further Russian aggression in Ukraine, and to deter Russian
Specialist in International
aggression against other countries. The United States also maintains sanctions on Russia in
Trade and Finance
response to (and to deter) malicious cyber-enabled activities and influence operations (including

election interference), the use of a chemical weapon, human rights abuses, the use of energy
Dianne E. Rennack
exports as a coercive or political tool, weapons proliferation, illicit trade with North Korea, and
Specialist in Foreign Policy
support to the governments of Syria and Venezuela. Many Members of Congress support a robust
Legislation
use of sanctions amid concerns about Russia’s international behavior and geostrategic intentions.

Sanctions related to Russia’s invasion of Ukraine are based mainly on four executive orders

(E.O.s) that President Obama issued in 2014. Legislation establishing sanctions specifically in
response to Russian actions includes the following:
 Sergei Magnitsky Rule of Law Accountability Act of 2012 (P.L. 112-208, Title IV; 22 U.S.C. 5811 note)
 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.)
 Ukraine Freedom Support Act of 2014, as amended (UFSA; P.L. 113-272; 22 U.S.C. 8921 et seq.)
 Countering Russian Influence in Europe and Eurasia Act of 2017, as amended (CRIEEA; P.L. 115-44,
Countering America’s Adversaries Through Sanctions Act [CAATSA], Title II; 22 U.S.C. 9501 et seq.)
 Protecting Europe’s Energy Security Act of 2019, as amended (PEESA; P.L. 116-92, Title LXXV; 22
U.S.C. 9526 note)
In imposing sanctions on Russia, the United States has coordinated many of its actions with the European Union (EU) and
others. As the invasion of Ukraine progressed in 2014, the Obama Administration considered EU support for sanctions to be
crucial, as the EU had more extensive trade and investment ties with Russia than the United States. Many policymakers and
observers view ongoing U.S.-EU cooperation in imposing sanctions as a tangible indication of U.S.-European solidarity,
frustrating Russian efforts to drive a wedge between transatlantic partners.
In terms of economic impact, studies suggest sanctions have had a negative but relatively modest impact on Russia’s growth.
Changes in world oil prices and the Coronavirus Disease 2019 (COVID-19) pandemic appear to have had a greater impact
than sanctions on the Russian economy. After oil prices rose in 2016, Russia’s economy began to strengthen even as
sanctions remained in place and, in some instances, were tightened. The Obama Administration and the EU designed
sanctions related to Russia’s invasion of Ukraine, in part, to impose longer-term pressures on Russia’s economy while
minimizing collateral damage to the Russian people and to the economic interests of the countries imposing sanctions.
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Contents
Introduction ..................................................................................................................................... 1
U.S. Sanctions on Russia: A Key Policy Tool ........................................................................... 1
How Effective Are Sanctions on Russia? .................................................................................. 2
About the Report ....................................................................................................................... 3
Use of Economic Sanctions to Further Foreign Policy and National Security Objectives .............. 3
Role of the President ................................................................................................................. 5
Role of Congress ....................................................................................................................... 5
Sanctions Implementation ......................................................................................................... 6
U.S. Sanctions on Russia ................................................................................................................. 6
Sanctions Related to Russia’s Invasion of Ukraine................................................................... 7
Specially Designated Nationals .......................................................................................... 7
Sectoral Sanctions Identifications ....................................................................................... 9
Ukraine-Related Legislation ............................................................................................. 10
Election Interference and Other Malicious Cyber-Enabled or Intelligence Activities ............ 12
Sanctions Authorities ........................................................................................................ 12
Related Actions ................................................................................................................. 14
Use of a Chemical Weapon ..................................................................................................... 19
CBW Act Sanctions .......................................................................................................... 19
Poisoning of Sergei Skripal............................................................................................... 20
Poisoning of Alexei Navalny ............................................................................................ 21
Human Rights Abuses and Corruption .................................................................................... 23
Sanctions Authorities ........................................................................................................ 23
Related Actions ................................................................................................................. 24
Section 241 “Oligarch” List and Related Sanctions ......................................................... 25
Nord Stream 2: Energy Exports as a Coercive or Political Tool ............................................. 27
Other Sanctions Programs ....................................................................................................... 28
Weapons Proliferation ....................................................................................................... 28
North Korea Sanctions Violations ..................................................................................... 30
Syria-Related Sanctions .................................................................................................... 31
Venezuela-Related Sanctions ............................................................................................ 32
Transnational Crime .......................................................................................................... 32
Terrorism ........................................................................................................................... 33
Restrictions on U.S. Government Funding ............................................................................. 33
Russian Countersanctions .............................................................................................................. 34
U.S. and EU Coordination on Sanctions ....................................................................................... 35
Comparing U.S. and EU Ukraine-Related Sanctions .............................................................. 35
EU Concerns About U.S. Sanctions After 2017 ...................................................................... 38
Other EU Sanctions in Response to Russian Activities .......................................................... 39
Economic Impact of Sanctions on Russia ..................................................................................... 40
Impact on Russia’s Economy Broadly .................................................................................... 40
Impact on Russian Firms ......................................................................................................... 41
Impact on Russian Government Finances ............................................................................... 43
Outlook .......................................................................................................................................... 44

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Figures
Figure 1. Economic Growth in Russia, 1994-2021 ....................................................................... 40

Tables
Table 1. U.S. Sanctions Related to Russia’s Invasion of Ukraine ................................................. 10

Table B-1. U.S. Sanctions on Russia for Which Designations Have Been Made ......................... 47
Table B-2. U.S. Sanctions on Russia for Which Designations Have Yet to Be Made ................... 52
Table D-1. U.S. and EU Sectoral Sanctions .................................................................................. 56
Table E-1. Russia’s Largest Firms and U.S. Sanctions ................................................................. 57

Appendixes
Appendix A. Legislative Abbreviations and Short Titles .............................................................. 46
Appendix B. U.S. Sanctions on Russia ......................................................................................... 47
Appendix C. Sanctions in Selected Russia-Related Legislation ................................................... 54
Appendix D. U.S. and EU Sectoral Sanctions ............................................................................... 56
Appendix E. Russian Firms and U.S. Sanctions ........................................................................... 57

Contacts
Author Information ........................................................................................................................ 58

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U.S. Sanctions on Russia

Introduction
U.S. Sanctions on Russia: A Key Policy Tool
Sanctions are a central element of U.S. policy to counter and deter malign Russian activities. The
United States maintains sanctions on Russia mainly in response to Russia’s 2014 invasion of
Ukraine, to reverse and deter further Russian aggression in Ukraine, and to deter Russian
aggression against other countries. The United States also maintains sanctions on Russia in
response to (and to deter) malicious cyber-enabled activities and influence operations (including
election interference), the use of a chemical weapon, human rights abuses, the use of energy
exports as a coercive or political tool, weapons proliferation, illicit trade with North Korea, and
support to the governments of Syria and Venezuela. Many Members of Congress support a robust
use of sanctions amid concerns about Russia’s international behavior and geostrategic intentions.
Sanctions related to Russia’s invasion of Ukraine are based mainly on national emergency
authorities granted the office of the President in the National Emergencies Act (NEA; P.L. 94-
412; 50 U.S.C. 1601 et seq.) and International Emergency Economic Powers Act (IEEPA; P.L.
95-223; 50 U.S.C. 1701 et seq.) and exercised by President Barack Obama in 2014 in a series of
executive orders (E.O.s 13660, 13661, 13662, 13685). The Obama, Trump, and Biden
Administrations have used these E.O.s to impose sanctions on hundreds of individuals and
entities (as well as on vessels and aircraft).
The executive branch also has used a variety of E.O.s and legislation to impose sanctions on
Russia and related individuals and entities in response to numerous other activities of concern.
Legislation that established sanctions specifically in response to Russian actions includes the
following:
 Sergei Magnitsky Rule of Law Accountability Act of 2012 (P.L. 112-208, Title
IV; 22 U.S.C. 5811 note)
 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.)
 Ukraine Freedom Support Act of 2014, as amended (UFSA; P.L. 113-272; 22
U.S.C. 8921 et seq.)
 Countering Russian Influence in Europe and Eurasia Act of 2017, as amended
(CRIEEA; P.L. 115-44, Countering America’s Adversaries Through Sanctions
Act [CAATSA], Title II; 22 U.S.C. 9501 et seq.)
 Protecting Europe’s Energy Security Act of 2019, as amended (PEESA; P.L. 116-
92, Title LXXV; 22 U.S.C. 9526 note)
In imposing sanctions on Russia, the United States has coordinated many of its actions with the
European Union (EU), the United Kingdom (UK), and others. As the invasion of Ukraine
progressed in 2014, the Obama Administration considered EU support for sanctions to be crucial,
as the EU had more extensive trade and investment ties with Russia than the United States. Many
policymakers and observers view ongoing U.S.-EU cooperation in imposing sanctions as a
tangible indication of U.S.-European solidarity, frustrating Russian efforts to drive a wedge
between transatlantic partners.
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How Effective Are Sanctions on Russia?
Many observers have debated the degree to which sanctions and the possibility of future sanctions
promote change in Russia’s behavior. Russia has deepened its hold over Ukraine’s occupied
Crimea region and separatist regions in eastern Ukraine. Russia has extended military operations
to nearby waters, interfering with maritime traffic to and from ports in eastern Ukraine, and since
2021 has engaged in a buildup of military forces near the Ukrainian border. As of mid-January
2022, however, Russia continues to nominally recognize Ukraine’s sovereignty over Russia-
controlled areas in eastern Ukraine and Russia-led military operations against Ukraine have been
limited to areas along the perimeter of the current conflict zone. Russia has not expanded its
military aggression further into Ukraine or to other states.
The relationship between sanctions and changes in other Russian malign behavior is also difficult
to determine. Sanctions in response to malicious cyber, influence, and other intelligence
activities, use of chemical weapons, human rights abuses, use of energy exports as a coercive or
political tool, weapons proliferation, illicit trade with North Korea, and support to Syria and
Venezuela are relatively limited and highly targeted. To the extent that Russia changes its
behavior, other factors besides sanctions could be responsible.
To the extent that Russian behavior does not change, it may be because Russian policymakers are
willing to incur the cost of sanctions in furtherance of Russia’s foreign policy goals. Sanctions
also might have the unintended effect of boosting internal support for the Russian government,
whether through appeals to nationalism or through Russian elites’ sense of self-preservation. In
addition, the Russian government has sought to minimize the impact of sanctions on favored
individuals and entities through subsidies, preferential contracts, import substitution policies, and
alternative markets (see “Impact on Russian Firms,” below).
In addition, the economic impact of sanctions may not be consequential enough to affect Russian
policy. Studies suggest sanctions have had a negative but relatively modest impact on Russia’s
growth and that changes in world oil prices and economic disruptions associated with the
Coronavirus Disease 2019 (COVID-19) pandemic have had a greater impact than sanctions.1
Although Russia faced several economic challenges in 2014-2015, including its longest recession
in almost 20 years, a collapse in global oil prices in 2014 had a larger impact than sanctions. As
oil prices recovered, Russia’s economy stabilized and grew at a modest pace. Economic
disruptions associated with the COVID-19 pandemic led to another contraction in 2020, followed
by recovery in 2021.
The modest macroeconomic effects of sanctions were largely by design. Most sanctions on
Russia do not broadly target the Russian economy or entire sectors. Rather, they consist of broad
restrictions against specific individuals and entities, as well as narrower restrictions on wider
groups of Russian companies and certain transactions with the Russian state. The United States
and the EU generally have sought to target individuals and entities responsible for offending
policies and/or associated with key Russian policymakers in a way that could get Russia to
change its behavior while minimizing collateral damage to the Russian people and to the
economic interests of the countries imposing sanctions.2 Moreover, some sanctions have been
intended to put only long-term pressure on the Russian economy, for instance by making it harder

1 International Monetary Fund (IMF), Russian Federation: Staff Report for the 2017 Article IV Consultation, July 10,
2017; and Daniel P. Ahn and Rodney D. Ludema, “The Sword and the Shield: The Economics of Targeted Sanctions,”
European Economic Review, vol. 130, November 2020.
2 See, for example, U.S. Department of the Treasury, “Treasury Sanctions Russian Officials, Members of the Russian
Leadership’s Inner Circle, and an Entity for Involvement in the Situation in Ukraine,” press release, March 20, 2014;
and Ahn and Ludema, “The Sword and the Shield,” 2020 (see footnote 1).
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for Russia to modernize its oil sector with access to Western technology and capital. The full
economic ramifications of such restrictions may have yet to materialize.
There is some evidence that U.S. sanctions on Russia can have broad economic effects if they are
applied to economically significant targets. At the same time, doing so may create instability in
global financial markets and opposition by U.S. allies, which generally have stronger economic
relationships with Russia than the United States does. In 2018, for example, the United States
imposed sanctions on Rusal, a global aluminum firm, which had broad effects that rattled Russian
and global financial markets. These sanctions marked the first time the United States had
designated a top Russian firm for sanctions that would affect nearly all economic activity and the
first time the Treasury Department appeared ready to enforce CRIEEA-mandated secondary
sanctions on persons that continued to conduct transactions with a sanctioned Russian firm. In
2019, however, the Treasury Department removed sanctions on Rusal and two related companies
after Kremlin-connected billionaire Oleg Deripaska, who is subject to sanctions, agreed to
relinquish his control over the three firms (for more, see “Section 241 “Oligarch” List and
Related Sanctions,
” below).
About the Report
This report provides a comprehensive overview of the use of sanctions in U.S. foreign policy
toward Russia. It is compartmentalized so that readers primarily interested in a particular issue,
for example sanctions in response to Russia’s use of chemical weapons, may find the relevant
information in a subsection of the report.
The report first provides an overview of U.S. sanctions authorities and tools, particularly as they
apply to Russia. It next describes various sanctions regimes that the executive branch has used to
impose sanctions in response to Russian activities or that are available for this purpose,
addressing authorities, tools, targets, and context. Third, the report briefly discusses
countersanctions Russia has introduced in response to U.S. and other sanctions. Fourth, it
addresses U.S. coordination with the EU on Russia sanctions policy. Finally, the report assesses
the economic impact of sanctions on Russia at the level of the national economy and individual
firms. Appendixes provide more detailed information regarding the use of various sanctions
authorities and Russia-related targets.
Use of Economic Sanctions to Further Foreign Policy
and National Security Objectives
Economic sanctions provide a range of tools Congress and the President may use to seek to alter
or deter the objectionable behavior of a foreign government, individual, or entity in furtherance of
U.S. national security or foreign policy objectives.
Scholars have broadly defined economic sanctions as “coercive economic measures taken against
one or more countries [or individuals or entities] to force a change in policies, or at least to
demonstrate a country’s opinion about the other’s policies.”3 Economic sanctions may include

3 Barry E. Carter, International Economic Sanctions: Improving the Haphazard U.S. Legal Regime (Cambridge:
Cambridge University Press, 1988), p. 4. Also see Gary Hufbauer, Jeffrey Schott, and Kimberly Elliott et al., Economic
Sanctions Reconsidered
, 3rd edition (Washington, DC: Peterson Institute for International Economics, 2007); and U.S.
International Trade Commission, Overview and Analysis of Current U.S. Unilateral Economic Sanctions, Investigation
No. 332-391, Publication 3124, Washington, DC, August 1998.
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limits on trade, such as overall restrictions or restrictions on particular exports or imports; the
blocking of assets and interest in assets subject to U.S. jurisdiction; limits on access to the U.S.
financial system, including limiting or prohibiting transactions involving U.S. individuals and
businesses; and restrictions on private and government loans, investments, insurance, and
underwriting. Sanctions also can include a denial of foreign assistance, government procurement
contracts, and participation or support in international financial institutions.4
Sanctions that target third parties—those not engaged in the objectionable activity subject to
sanctions but engaged with the individuals or entities that are—are popularly referred to as
secondary sanctions. Secondary sanctions often are constructed to deter sanctions evasion,
penalizing those that facilitate a means to avoid detection or that provide alternative access to
finance.
The United States has applied a variety of sanctions in response to malign Russian activities.
Most sanctions on Russia, including most sanctions established by executive order (see “Role of
the President,”
below), do not target the Russian state directly. Instead, they consist of
designations of specific individuals, entities, vessels, and aircraft on the Specially Designated
Nationals and Blocked Persons List (SDN) of the Treasury Department’s Office of Foreign Assets
Control (OFAC). Sanctions block the U.S.-based assets of individuals and entities designated as
SDNs and generally prohibit U.S. individuals and entities from engaging in transactions with
them.5 In addition, the Secretary of State, in consultation with the Secretary of Homeland
Security and Attorney General, is tasked with denying entry into the United States of, or revoking
visas granted to, designated foreign nationals.
Sanctions in response to Russia’s invasion of Ukraine also consist of sectoral sanctions. Often,
sectoral sanctions broadly apply to specific sectors of an economy. In the case of sanctions on
Russia, sectoral sanctions have a narrower meaning; they apply to specific entities in Russia’s
financial, energy, and defense sectors that OFAC has identified for inclusion on the Sectoral
Sanctions Identifications (SSI) List. These sectoral sanctions prohibit U.S. individuals and entities
from engaging in specific kinds of transactions related to lending, investment, and/or trade with
entities on the SSI List, but they permit other transactions.
Another major category of sanctions on Russia consists of a presumption of denial to designated
end users for export licenses. The Department of Commerce’s Bureau of Industry and Security
(BIS) places entities subject to export restrictions on the Entity List (Supplement No. 4 to Part
744 of the Export Administration Regulations).6

4 Not everyone agrees on what the sanctions toolbox includes. For example, some characterize export controls, limits
on foreign assistance, or visa denials as foreign policy tools that are less about changing the target’s behavior than
about administering U.S. foreign policy while meeting the requirements and obligations the United States assumes
under treaties, international agreements, and its own public laws. See Senator Jesse Helms, “What Sanctions Epidemic?
U.S. Business’ Curious Crusade,” Foreign Affairs, vol. 78, no. 1 (January/February 1999), pp. 2-8.
5 More recently, some sanctions regimes have included the designation of vessels and aircraft owned or controlled by a
designated individual or entity in order to preempt sanctions evasion by means of re-registration or reflagging.
6 The Department of Commerce’s Bureau of Industry and Security (BIS) established an Entity List in 1997 to oversee
U.S. compliance with international treaty and agreement obligations to control the export of materials related to
weapons of mass destruction. Subsequently, the Entity List expanded to include entities engaged in activities
considered contrary to U.S. national security and/or foreign policy interests. U.S. Department of Commerce, “Entity
List,” at https://www.bis.doc.gov/index.php/policy-guidance/lists-of-parties-of-concern/entity-list.
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U.S. Sanctions on Russia

Role of the President
The President, for a variety of reasons related to constitutional construction and legal challenges
throughout U.S. history, holds considerable authority when economic sanctions are used in U.S.
foreign policy.7 If Congress enacts sanctions in legislation, the President is to adhere to the
provisions of the legislation but is responsible for determining the individuals and entities to be
subject to sanctions.
The President also often has the authority to be the sole decisionmaker in initiating and imposing
sanctions. The President does so by determining, pursuant to the International Emergency
Economic Powers Act (IEEPA), that there has arisen an “unusual and extraordinary threat, which
has its source in whole or substantial part outside the United States, to the national security,
foreign policy, or economy of the United States.”8 The President then declares that a national
emergency exists, as provided for in the National Emergencies Act (NEA), submits the
declaration to Congress, and establishes a public record by publishing it in the Federal Register.9
Under a national emergency, the President may invoke the authorities granted his office in IEEPA
to investigate, regulate, or prohibit transactions in foreign exchange, use of U.S. banking
instruments, the import or export of currency or securities, and transactions involving property or
interests in property under U.S. jurisdiction.10
President Obama invoked NEA and IEEPA authorities to declare that Russia’s 2014 invasion of
Ukraine constituted a threat to the United States. On that basis, he declared the national
emergency on which most sanctions related to Russia’s invasion of Ukraine are based. In
addition, President Obama and President Trump invoked NEA and IEEPA authorities to declare
national emergencies related to cyber-enabled malicious activities and election interference.
President Biden has invoked NEA and IEEPA authorities to declare a national emergency related
to a number of specified harmful foreign activities undertaken by or on behalf of the Russian
government.
Role of Congress
Congress influences which foreign policy and national security concerns the United States
responds to with sanctions by enacting legislation to authorize, and in some instances require, the
President to use sanctions. Congress has taken the lead in authorizing or requiring the President
(or executive branch) to use sanctions in an effort to deter weapons proliferation, international
terrorism, illicit narcotics trafficking, human rights abuses, regional instability, cyberattacks,
corruption, and money laundering. Legislation can define what sanctions the executive branch is
to apply, as well as the conditions that need to be met before these sanctions may be lifted.

7 The Constitution divides foreign policy powers between the executive and legislative branches in a way that requires
each branch to remain engaged with and supportive of, or responsive to, the interests and intentions of the other. See
U.S. Congress, House Committee on Foreign Affairs, Strengthening Executive-Legislative Consultation on Foreign
Policy
, Congress and Foreign Policy Series (No. 8), 98th Cong., 1st sess., October 1983, pp. 9-11.
8 International Emergency Economic Powers Act (IEEPA); P.L. 95-223, §202(a); 50 U.S.C. 1701(a). For more, see
CRS Report R45618, The International Emergency Economic Powers Act: Origins, Evolution, and Use, coordinated by
Christopher A. Casey.
9 National Emergencies Act (NEA); P.L. 94-412, §201; 50 U.S.C. 1621.
10 IEEPA, §203; 50 U.S.C. 1702.
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One limitation on the role of Congress in establishing sanctions originates in the U.S.
Constitution’s bill of attainder clause.11 Congress may not enact legislation that “legislatively
determines guilt and inflicts punishment upon an identifiable individual without provision of the
protections of a judicial trial.”12 In other words, Congress may enact legislation that broadly
defines categories of sanctions targets and objectionable behavior, but it is left to the President to
“[determine] guilt and [inflict] punishment”—that is, to populate the target categories with
specific individuals and entities.
Sanctions Implementation
In the executive branch, several agencies have varying degrees of responsibility in implementing
and administering sanctions. Primary agencies, broadly speaking, have responsibilities as follows:
 Department of the Treasury’s OFAC designates SDNs to be subject to the
blocking of U.S.-based assets; designates non-SDNs for which investments or
transactions may be subject to conditions or restrictions; prohibits transactions;
licenses transactions relating to exports and investments (and limits those
licenses); restricts access to U.S. financial services; restricts transactions related
to travel, in limited circumstances; and (with regard to Russia sanctions)
identifies entities for placement on the SSI List as subject to investment and trade
limitations.
 Department of State restricts visas, arms sales, and foreign aid; implements arms
embargos required by the United Nations; prohibits the use of U.S. passports to
travel, in limited circumstances; and downgrades or suspends diplomatic
relations.
 Department of Commerce’s BIS restricts licenses for commercial exports, end
users, and destinations.
 Department of Defense restricts arms sales and other forms of military
cooperation.
 Department of Justice investigates and prosecutes violations of sanctions and
export laws.13
U.S. Sanctions on Russia
The United States maintains sanctions on Russia related to Russia’s 2014 invasion of Ukraine,
malicious cyber activities and influence operations (including election interference), use of
chemical weapons, human rights abuses, use of energy exports as a coercive or political tool,
weapons proliferation, illicit trade with North Korea, support to the governments of Syria and
Venezuela, and other activities.

11 “No Bill of Attainder or ex post facto Law Will Be Passed.” U.S. Constitution, Article I, §9, clause 3.
12 See out-of-print CRS Report R40826, Bills of Attainder: The Constitutional Implications of Congress Legislating
Narrowly
, available to congressional offices on request.
13 Other departments, bureaus, agencies, and offices of the executive branch also weigh in, but to a lesser extent. The
Department of Homeland Security, Attorney General, and Federal Bureau of Investigation, for example, all might
review decisions relating to visas; Customs and Border Protection has a role in monitoring imports; the Department of
Energy has responsibilities related to export control of nuclear materials; and the National Security Council reviews
foreign policy and national security determinations and executive orders as part of the interagency process.
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For an overview of Russia sanctions authorities and designations, see Appendix B.
Sanctions Related to Russia’s Invasion of Ukraine
OFAC has issued most U.S. sanctions designations of Russian individuals and entities in response
to Russia’s 2014 invasion and occupation of Ukraine’s Crimea region and parts of eastern
Ukraine. In 2014, the Obama Administration said it would impose increasing costs on Russia, in
coordination with the EU and others, until Russia “abides by its international obligations and
returns its military forces to their original bases and respects Ukraine’s sovereignty and territorial
integrity.”14
The United States has imposed sanctions related to Russia’s invasion of Ukraine on at least 735
individuals, entities, vessels, and aircraft that OFAC has placed on its Specially Designated
Nationals List (SDN) or Sectoral Sanctions Identification List (SSI) (see Table 1 and Table B-1).
The basis for most of these sanctions is a series of four executive orders (E.O.s 13660, 13661,
13662, and 13685) that President Obama issued in 2014.15 In addition, the Department of
Commerce’s BIS denies export licenses for military, dual-use, or energy-related goods to
designated end users, most of which also are subject to Treasury-administered sanctions.
Two of President Obama’s Ukraine-related E.O.s target specific objectionable behavior. E.O.
13660 provides for sanctions against those the President determines have undermined democratic
processes or institutions in Ukraine; undermined Ukraine’s peace, security, stability, sovereignty,
or territorial integrity; misappropriated Ukrainian state assets; or illegally asserted governmental
authority over any part of Ukraine. E.O. 13685 prohibits U.S. business, trade, or investment in
occupied Crimea and provides for sanctions against those the President determines have operated
in, or been the leader of an entity operating in, occupied Crimea.
The other two E.O.s provide for sanctions against a broader range of targets. E.O. 13661 provides
for sanctions against Russian government officials, those who offer them support, and those
operating in the Russian arms sector. E.O. 13662 provides for sanctions against individuals and
entities that operate in key sectors of the Russian economy, as determined by the Secretary of the
Treasury.
Specially Designated Nationals
OFAC established four SDN programs based on the four Ukraine-related E.O.s: two for those
found to have engaged in specific activities related to the destabilization and invasion of Ukraine,
and two for broader groups of targets. As of January 2022, OFAC has designated at least 445
individuals, entities, vessels, and aircraft under the four Ukraine-related SDN programs (see
Table 1 and Table B-1).
OFAC draws on E.O. 13660 to designate individuals and entities for their role in destabilizing
and invading Ukraine. Designees mainly include former Ukrainian officials (including ex-

14 White House, “Fact Sheet: Ukraine-Related Sanctions,” March 17, 2014.
15 The President declared that events in Ukraine constituted a national emergency in the first executive order; the
subsequent three orders built on and expanded that initial declaration. E.O. 13660 must be extended annually to remain
in force; the President extended it most recently on March 2, 2021. Executive Order (E.O.) 13660 of March 6, 2014,
“Blocking Property of Certain Persons Contributing to the Situation in Ukraine,” 79 Federal Register 13493; E.O.
13661 of March 16 [17], 2014, “Blocking Property of Additional Persons Contributing to the Situation in Ukraine,” 79
Federal Register 15535; E.O. 13662 of March 20, 2014, “Blocking Property of Additional Persons Contributing to the
Situation in Ukraine,” 79 Federal Register 16169; and E.O. 13685 of December 19, 2014, “Blocking Property of
Certain Persons and Prohibiting Certain Transactions with Respect to the Crimea Region of Ukraine,” 79 Federal
Register
77357.
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President Viktor Yanukovych and a former prime minister), de facto officials in occupied Crimea
and eastern Ukraine, Russia-based fighters and patrons, and associated companies or
organizations.
OFAC draws on E.O. 13685 to designate primarily Russian or Crimea-based companies and
subsidiaries that operate in occupied Crimea (including individuals and entities involved in
construction and operation of the Russia-Crimea railway and a prison in Crimea known as a site
of human rights abuses). In September 2019, OFAC drew on E.O. 13685 to designate nine
individuals, entities, and vessels for evading Crimea-related sanctions in furtherance of an illicit
scheme to deliver fuel to Russian forces in Syria.
OFAC draws on E.O. 13661 (and, in some cases, E.O. 13662) to designate a wider circle of
Russian government officials, members of parliament, heads of state-owned companies, other
prominent businesspeople and associates, including individuals the Treasury Department has
considered part of Russian President Vladimir Putin’s “inner circle,” and related entities.16
Pursuant to these E.O.s (and sometimes simultaneously pursuant to other authorities), OFAC also
has designated officials and state-connected individuals and entities in response to other Russian
activities, including malign influence operations worldwide and the poisoning and imprisonment
of Russian opposition figure Alexei Navalny.
Among the designated government officials and heads of state-owned companies are Russia’s
minister of internal affairs, prosecutor general, and Security Council secretary; directors of the
Federal Security Service (FSB), Foreign Intelligence Service (SVR), National Guard Troops, and
the Federal Penitentiary Service; the chairs of both houses of parliament; and the chief executive
officers of state-owned oil company Rosneft, gas company Gazprom, defense and technology
conglomerate Rostec, and banks VTB and Gazprombank. OFAC also has drawn on E.O. 13661 to
designate four Russian border guard officials for their role in a 2018 attack against Ukrainian
naval vessels in the Black Sea near occupied Crimea.
OFAC has designated several politically connected Russian billionaires and companies they own
or control under E.O. 13661 or E.O. 13662.17 Designees include 9 of Russia’s wealthiest
individuals, including 4 of the top 20, as estimated in 2021 by Forbes.18 Of these nine
billionaires, five were designated in April 2018 as “oligarchs … who profit from [Russia’s]
corrupt system.”19
Under E.O. 13661 and other authorities, OFAC has designated Yevgeny Prigozhin, a wealthy
state-connected businessperson alleged to be a lead financial backer of private military companies
(PMCs) that have operated in Ukraine and elsewhere (see “Prigozhin Network” below). These
PMCs include the Wagner Group, also subject to U.S. sanctions.
OFAC has designated other holdings owned or controlled by SDNs. These holdings include Bank
Rossiya, which the Treasury Department has described as the “personal bank” of Russian senior
officials;20 other privately held banks and financial services companies (e.g., SMP Bank and the

16 See, for example, U.S. Department of the Treasury, “Treasury Sanctions Russian Officials, Members of the Russian
Leadership’s Inner Circle, And An Entity For Involvement In The Situation In Ukraine,” press release, March 20, 2014.
17 E.O. 13661, for being a Russian government official or supporting a senior government official, and E.O. 13662, for
operating in the energy sector.
18 “The World’s Billionaires,” Forbes, 2021, at https://www.forbes.com/billionaires/list/#version:static_country:Russia.
19 U.S. Department of the Treasury, “Treasury Designates Russian Oligarchs, Officials, and Entities in Response to
Worldwide Malign Activity,” press release, April 6, 2018.
20 U.S. Department of the Treasury, “Treasury Sanctions Russian Officials, Members Of The Russian Leadership’s
Inner Circle, And An Entity For Involvement In The Situation In Ukraine,” press release, March 20, 2014.
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Volga Group); gas pipeline construction company Stroygazmontazh; construction company
Stroytransgaz; and vehicle manufacturer GAZ Group. Private aluminum company Rusal, electric
company EuroSibEnergo, and the related En+ Group were delisted in 2019 after being designated
the year before (for more, see “Section 241 “Oligarch” List and Related Sanctions,” below).
Designated entities also include several defense and arms firms, such as the state-owned United
Shipbuilding Corporation, Almaz-Antey (air defense systems and missiles), Uralvagonzavod
(tanks and other military equipment), NPO Mashinostroyenia (missiles and rockets), and several
subsidiaries of the state-owned defense and hi-tech conglomerate Rostec, including the
Kalashnikov Group (firearms).
Sectoral Sanctions Identifications
OFAC has used E.O. 13662 mainly as the basis for identifying entities for inclusion on the SSI
List. Individuals and entities under U.S. jurisdiction are restricted from engaging in specific
transactions with entities on the SSI List, which OFAC identifies as subject to one of four
directives under the E.O. SSI restrictions apply to new equity investment and financing (other
than 14-day lending) for identified entities in Russia’s financial sector (Directive 1); new
financing (other than 60-day lending) for identified entities in Russia’s energy sector (Directive
2); and new financing (other than 30-day lending) for identified entities in Russia’s defense sector
(Directive 3).21 A fourth directive prohibits U.S. trade with identified entities related to the
development of Russian deepwater, Arctic offshore, or shale projects that have the potential to
produce oil and, amended as a result of requirements enacted in CRIEEA in 2017, such projects
worldwide in which those entities have an ownership interest of at least 33% or a majority of
voting interests.
As of January 2022, OFAC has placed 13 major Russian companies and more than 275 of their
subsidiaries and affiliates on the SSI List. The SSI List includes major state-owned companies in
the financial, energy, and defense sectors; it does not include all companies in those sectors. The
parent entities on the SSI List, under their respective directives, consist of the following:
 Five large state-owned banks: Sberbank, VTB Bank, Gazprombank,
Rosselkhozbank, and VEB (rebranded VEB.RF in 2018), which “acts as a
development bank and payment agent for the Russian government”;22
 State-owned oil companies Rosneft and Gazpromneft, pipeline company
Transneft, and private gas producer Novatek;
 State-owned defense and hi-tech conglomerate Rostec; and
 For restrictions on transactions related to deepwater, Arctic offshore, or shale oil
projects, Rosneft and Gazpromneft, private companies Lukoil and
Surgutneftegaz, and state-owned energy company Gazprom (Gazpromneft’s
parent company).

21 Directive 1 has been amended twice to narrow lending windows from, initially, 90 days (July 2014) to 30 days
(September 2014) to 14 days (September 2017). The lending window in Directive 2 has been narrowed once, from 90
days (July 2014) to 60 days (September 2017). Directives are available at https://www.treasury.gov/resource-center/
sanctions/Programs/Pages/ukraine.aspx.
22 The Administration also designated the Bank of Moscow, which later became a subsidiary of VTB Bank. U.S.
Department of the Treasury, “Announcement of Treasury Sanctions on Entities Within the Financial Services and
Energy Sectors of Russia, Against Arms or Related Materiel Entities, and those Undermining Ukraine’s Sovereignty,”
press release, July 16, 2014.
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Ukraine-Related Legislation
In addition to issuing four Ukraine-related executive orders in 2014, President Obama signed into
law the Support for the Sovereignty, Integrity, Democracy, and Economic Stability of Ukraine Act
(SSIDES) on April 3, 2014, and the Ukraine Freedom Support Act (UFSA) on December 18,
2014. SSIDES was introduced in the Senate on March 12, 2014, six days after President Obama
issued the first Ukraine-related E.O., declaring a national emergency with respect to Ukraine. The
President signed UFSA into law the day before he issued his fourth Ukraine-related E.O.,
prohibiting trade and investment with occupied Crimea. CRIEEA, which President Trump signed
into law on August 2, 2017, amended SSIDES and UFSA, among other measures (see Table 1
and “Countering Russian Influence in Europe and Eurasia Act of 2017” text box, below).
Both SSIDES and UFSA expand on the actions the Obama Administration took in response to
Russia’s invasion of Ukraine. President Obama did not cite SSIDES or UFSA as an authority for
designations or other sanctions actions, however.23 The Trump Administration issued three human
rights-related designations pursuant to SSIDES.
Some sanctions authorities in SSIDES and UFSA overlap with steps taken by the President in
issuing E.O.s under emergency authorities. Many individuals and entities OFAC designated for
their role in destabilizing Ukraine, for example, could have been designated pursuant to SSIDES.
Similarly, some of the individuals OFAC designated in April 2018 as “oligarchs and elites who
profit from [Russia’s] corrupt system” potentially could have been designated pursuant to the
authority in SSIDES that provides for sanctions against those responsible for significant
corruption.24 In addition, Russian arms exporter Rosoboronexport, subject to sanctions under
UFSA, is subject to sanctions under other authorities (see “Weapons Proliferation”).
SSIDES and UFSA contain additional sanctions provisions that the executive branch could use.
These include sanctions against Russian individuals and entities for corruption, arms transfers to
Syria and separatist territories, and energy export cutoffs. They also include potentially wide-
reaching secondary sanctions against foreign individuals and entities that facilitate significant
transactions for Russia sanctions designees, help them to evade sanctions, or make significant
investments in certain oil projects in Russia (for details, see Appendix C).
Table 1. U.S. Sanctions Related to Russia’s Invasion of Ukraine
(authorities, targets, and Treasury designees)
Designations
Authorities
Targets
(as of 1/2022)
Executive Order (E.O.)
Those responsible for undermining Ukraine’s democracy;
128 individuals, 24
13660; Countering
threatening its peace, security, stability, sovereignty, or
entities
Russian Influence in
territorial integrity; misappropriating assets; and/or il egally
Europe and Eurasia Act asserting government authority.
of 2017 (CRIEEA; P.L.
115-44, Title II; 22
U.S.C. 9501 et seq.)

23 In his signing statement, President Obama said the Administration did “not intend to impose sanctions under this law,
but the Act gives the Administration additional authorities that could be utilized, if circumstances warranted.” White
House, “Statement by the President on the Ukraine Freedom Support Act,” December 18, 2014.
24 U.S. Department of the Treasury, “Treasury Designates Russian Oligarchs, Officials, and Entities in Response to
Worldwide Malign Activity,” press release, April 6, 2018.
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Designations
Authorities
Targets
(as of 1/2022)
E.O. 13661; P.L. 115-44 Russian government officials; those operating in Russia’s arms 109 individuals, 78
or related materiel sector; entities owned or control ed by a
entities, 3 aircraft, 1
senior Russian government official; those acting on behalf of,
vessel
or materially assisting or supporting, a senior Russian
government official.
E.O. 13662; P.L. 115-44 Entities and individuals operating in specified sectors of the
290 entities (SSI);
Russian economy. Four Treasury directives specify financial
6 individuals, 13
services, energy (including deepwater, Arctic offshore, and
entities (SDN)
shale oil development projects), and defense.
E.O. 13685; P.L. 115-44 Prohibits U.S. business, trade, or investment in occupied
75 entities, 10
Crimea and provides for sanctions against those the
individuals, 7 vessels
President determines have operated in, or been the leader of
an entity operating in, occupied Crimea.
Support for the
Those responsible for violence and human rights abuses
2 individuals, 1 entity;
Sovereignty, Integrity,
during antigovernment protests in Ukraine in 2013-2014;
authorities and
Democracy, and
undermining Ukraine’s peace, security, stability, sovereignty,
categories of targets
Economic Stability of
or territorial integrity; and serious human rights abuses in
partially overlap with
Ukraine Act of 2014
territory forcibly occupied or control ed by Russia.
executive orders and
(SSIDES; P.L. 113-95, as Russian government officials, family members, and close
related designations.
amended by P.L. 115-
associates for acts of significant corruption.
44; 22 U.S.C. 8901 et
seq.)
Foreign individuals and entities for violating Ukraine- or
cyber-related sanctions or facilitating significant transactions
for individuals, their family members, and entities subject to
sanctions on Russia.
Ukraine Freedom
State-run arms exporter Rosoboronexport.
No designations
Support Act of 2014
Russian individuals and entities for conducting weapons
specifically attributed
(UFSA; P.L. 113-272, as
transfers to Syria, Ukraine, Georgia, Moldova, and potentially
to the act, to date.
amended by P.L. 115-
other countries.
Rosoboronexport is
44; 22 U.S.C. 8921 et
designated pursuant to
seq.)
Foreign individuals and entities for investing in deepwater,
the Syria-related E.O.
Arctic offshore, or shale oil projects in Russia.
13582, in addition to
Foreign financial institutions for facilitating significant
sectoral sanctions
transactions (1) related to Russia’s weapons transfers to
pursuant to E.O.
Syria, Ukraine, Georgia, Moldova, and potentially other
13662, Directive 3.
countries; (2) related to deepwater, Arctic offshore, or shale
oil projects in Russia; and (3) for individuals and entities
subject to sanctions related to Russia’s invasion of Ukraine.
Withholding by Gazprom of significant natural gas supplies
from NATO member states or countries such as Ukraine,
Georgia, or Moldova.
Source: U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC); Congressional Research
Service (CRS).
Notes: The total number of SDNs under the Ukraine-related E.O.s is 445. Three individuals and six entities
have been designated twice under the Ukraine-related E.O.s.
SSI: Sectoral Sanctions Identifications List, SDN: Special y Designated Nationals and Blocked Persons List.
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Election Interference and Other Malicious Cyber-Enabled or
Intelligence Activities

Sanctions Authorities
The executive branch draws on national emergency authorities and other legislation to impose
sanctions for a range of malicious cyber-enabled activities, influence operations (including
election interference), and other intelligence activities in the United States or elsewhere, including
activities the United States has attributed to the Russian government. The relevant authorities are
as follows:
E.O. 13694, as amended by E.O. 13757. On April 1, 2015, President Obama issued E.O. 13694,
invoking national emergency authorities to declare that “the increasing prevalence and severity of
malicious cyber-enabled activities originating from, or directed by persons located … outside the
United States, constitute an unusual and extraordinary threat.” E.O. 13694 targets those who
engage in cyberattacks (1) against critical infrastructure, (2) for financial or commercial gain, or
(3) to significantly disrupt the availability of a computer or network.25
On December 28, 2016, President Obama issued E.O. 13757, which amended E.O. 13694 to
establish sanctions against those engaged in “tampering with, altering, or causing a
misappropriation of information with the purpose or effect of interfering with or undermining
election processes or institutions.”26
Nine days after President Obama issued E.O. 13757, the Office of the Director of National
Intelligence (ODNI) released an unclassified Intelligence Community Assessment on Russian
activities and intentions related to the 2016 U.S. presidential election. The assessment stated that
the Central Intelligence Agency, the Federal Bureau of Investigation, and the National Security
Agency had “high confidence” that Russian President Vladimir Putin had “ordered an influence
campaign in 2016 aimed at the U.S. presidential election.”27
CRIEEA, Section 224. CRIEEA, enacted in August 2017, codified E.O. 13694, as amended, and,
in Section 224, expanded 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.”28

25 E.O. 13694 did not target a specific state, entity, or individual. President Obama issued the E.O. four months after the
Sony Pictures hack, which the U.S. intelligence community assessed had originated in North Korea, and 10 months
after the U.S. Department of Justice indicted several Chinese military officers for cyber-related espionage. E.O. 13694
of April 1, 2015, “Blocking the Property of Certain Persons Engaging in Significant Malicious Cyber-Enabled
Activities,” 80 Federal Register 18077. E.O. 13694, as amended, must be extended annually to remain in force; the
President extended it most recently on March 29, 2021.
26 E.O. 13757 of December 28, 2016, “Taking Additional Steps to Address the National Emergency with Respect to
Significant Malicious Cyber-Enabled Activities,” 82 Federal Register 1.
27 Office of the Director of National Intelligence, Assessing Russian Activities and Intentions in Recent U.S. Elections,
Intelligence Community Assessment 2017-01D, January 6, 2017.
28 The Countering Russian Influence in Europe and Eurasia Act of 2017, as amended (CRIEEA; P.L. 115-44, Title II,
§224; 22 U.S.C. 9524(d)) defines these activities to include the following:
(1) significant efforts—(A) to deny access to or degrade, disrupt, or destroy an information and
communications technology system or network; or (B) to exfiltrate, degrade, corrupt, destroy, or
release information from such a system or network without authorization for purposes of—(i)
conducting influence operations; or (ii) causing a significant misappropriation of funds, economic
resources, trade secrets, personal identifications, or financial information for commercial or
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E.O. 13848. On September 12, 2018, President Trump issued E.O. 13848, invoking new national
emergency authorities to declare that “the ability of persons located … outside the United States
to interfere in or undermine public confidence in United States elections, including through the
unauthorized accessing of election and campaign infrastructure or the covert distribution of
propaganda and disinformation, constitutes an unusual and extraordinary threat.”29 E.O. 13848
also states that “the proliferation of digital devices and internet-based communications has
created significant vulnerabilities and magnified the scope and intensity of the threat of foreign
interference.” In addition, it states that “there has been no evidence of a foreign power altering the
outcome or vote tabulation in any United States election.”
E.O. 13848 provides for sanctions against foreign individuals and entities that have “directly or
indirectly engaged in, sponsored, concealed or otherwise been complicit in foreign interference in
a United States election.” The E.O. requires the Director of National Intelligence to make an
initial assessment regarding foreign interference within 45 days of an election and the Attorney
General and Secretary of Homeland Security to issue a second report regarding the impact of
such interference on election and campaign infrastructure within another 45 days.30 In addition,
the E.O. requires the Secretary of State and the Secretary of the Treasury to recommend to the
President the appropriateness of additional sanctions, including against the largest business
entities of the country determined to have interfered in elections, including at least one each from
the financial services, defense, energy, technology, and transportation sectors.
CRIEEA, Section 231. CRIEEA, Section 231, also responds to malicious cyber-enabled
activities by establishing sanctions against those who engage in “significant transactions” with the
Russian defense or intelligence sectors, including arms sales.
E.O. 14024. On April 15, 2021, President Biden issued E.O. 14024 to impose sanctions against
those responsible for or who have engaged in malicious cyber-enabled activities, election
interference, or the undermining of democratic processes or institutions on behalf of the Russian
government, among other “harmful foreign activities.”31
The other “harmful foreign activities” included in E.O. 14024 include transnational corruption;
the unlawful killing or harming of U.S. persons or U.S. ally or partner nationals; activities that
“undermine the peace, security, political stability, or territorial integrity of the United States, its
allies, or its partners”; and the circumvention of U.S. sanctions. The E.O. targets Russian
government officials and entities (and officials’ spouses and families); persons operating in
Russia’s technology, defense, and related materiel or other sectors; and Russian persons who
support governments subject to U.S. sanctions or who disrupt energy supplies to Europe or Asia.

competitive advantage or private financial gain; (2) significant destructive malware attacks; and (3)
significant denial of service activities.
29 Executive Order 13848 of September 12, 2018, “Imposing Certain Sanctions in the Event of Foreign Interference in a
United States Election,” 83 Federal Register 46843. E.O. 13848 must be extended annually to remain in force; the
President extended it most recently on September 7, 2021.
30 The FY2020 National Defense Authorization Act (NDAA; P.L. 116-92, §5304(a)(1); 50 U.S.C. 3371) includes a
separate requirement for the Director of National Intelligence, in coordination with the Under Secretary of Homeland
Security for Intelligence and Analysis and the Director of the Federal Bureau of Investigation, to “make publicly
available on an internet website an advisory report on foreign counterintelligence and cybersecurity threats to
campaigns of candidates for Federal office.”
31 Executive Order 14024 of April 15, 2021, “Blocking Property with Respect to Specified Harmful Foreign Activities
of the Government of the Russian Federation,” 86 Federal Register 20249.
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Related Actions32
U.S. Election Interference
Under one or more of these authorities, the United States has designated at least 68 individuals
and related entities, vessels, and aircraft for activities related to Russian interference in U.S.
elections. Several of the designated individuals also have been indicted by the Department of
Justice for related crimes. These designations include the following:
 Russia’s leading intelligence agency (Federal Security Service, or FSB), military
intelligence agency (Main Intelligence Directorate, or GRU), four GRU officers,
and three companies that allegedly facilitated election-related cyberattacks
(designated in December 2016).33
 The Internet Research Agency (IRA), 12 of its employees, alleged financial
backer Yevgeny Prigozhin, and two of Prigozhin’s companies. All of these were
indicted previously by the Department of Justice Special Counsel’s Office for
related crimes (March 2018).34
 Nine GRU officers indicted previously by the Department of Justice Special
Counsel’s Office for crimes related to election interference (December 2018).35
 Six designees “related to Project Lakhta, a broad Russian effort that includes the
IRA.” 36 The designees included an individual whom the Department of Justice
charged in September 2018 for conspiracy to defraud the United States related to
efforts “to interfere in the U.S. political system, including the 2018 midterm
election” (December 2018).37
 In response to Russian efforts to interfere in the 2018 U.S. midterm elections,
OFAC issued the first designations under E.O. 13848. Designees included the
IRA, Prigozhin, and four IRA employees (all previously designated under E.O.
13694, as amended), as well as two other IRA employees, three Prigozhin-owned
aircraft and a yacht, and three associated front companies (September 2019).

32 For more on Russian intelligence agencies and their cyber operations, see CRS Report R46616, Russian Military
Intelligence: Background and Issues for Congress
, by Andrew S. Bowen, and CRS In Focus IF11718, Russian Cyber
Units
, by Andrew S. Bowen.
33 At this time, the Administration also declared 35 Russian diplomatic personnel personae non grata in response to
what Obama Administration officials characterized as increased harassment of U.S. diplomatic personnel in Russia.
The Administration also denied Russian officials access to two Russian government-owned compounds, located in
Maryland and New York, which President Obama said Russia was using for intelligence-related purposes. White
House, “Fact Sheet: Actions in Response to Russian Malicious Cyber Activity and Harassment,” December 29, 2016;
and White House, “Statement by the President on Actions in Response to Russian Malicious Cyber Activity and
Harassment,” December 29, 2016.
34 For the Special Counsel’s indictment, see U.S. Department of Justice, “Grand Jury Indicts Thirteen Russian
Individuals and Three Russian Companies for Scheme to Interfere in the United States Political System,” press release,
February 16, 2018.
35 For the Special Counsel’s indictment, see U.S. Department of Justice, “Grand Jury Indicts 12 Russian Intelligence
Officers for Hacking Offenses Related to the 2016 Election,” press release, July 13, 2018.
36 U.S. Department of the Treasury, “Treasury Targets Russian Operatives over Election Interference, World Anti-
Doping Agency Hacking, and Other Malign Activities,” press release, December 19, 2018.
37 U.S. Department of Justice, “Russian National Charged with Interfering in U.S. Political System,” press release,
October 19, 2018.
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 Three IRA employees for supporting the IRA’s cryptocurrency accounts
(September 2020).
 Ukrainian Member of Parliament Andrii Derkach in response to Russian-linked
efforts to interfere in the 2020 U.S. presidential election. The Treasury
Department characterized Derkach as “an active Russian agent for over a
decade” (September 2020).38
 Seven individuals and four entities in Ukraine that OFAC determined to be “part
of a Russia-linked foreign influence network” associated with Derkach (January
2021).39
 At least four individuals and entities for “attempt[ing] to influence the 2020 U.S.
presidential election at the direction of the leadership of the Russian
government.” Designees included a Russian first deputy presidential chief of
staff, a political consultant Treasury said also interfered in the 2016 U.S.
presidential election, and two Russian intelligence-controlled “disinformation
outlets.”40 OFAC also designated three other intelligence-controlled outlets and a
related individual for broader disinformation activities (April 2021).
Prigozhin Network
Since 2016, OFAC has imposed sanctions on a network of individuals and entities linked to
Russian financier Yevgeny Prigozhin. In addition to the above-mentioned sanctions imposed in
response to U.S. election interference, OFAC has applied sanctions to Prigozhin, two of his
companies, and the allegedly Prigozhin-financed PMC Wagner Group and its leader for activities
related to Russia’s invasion of Ukraine.
In July and September 2020, OFAC imposed sanctions on 13 Prigozhin-linked individuals and
entities in Sudan, the Central African Republic, Hong Kong, and Thailand. OFAC said these
designees had “directly facilitated Prigozhin’s global operations,” exploited natural resources in
Sudan and the Central African Republic, “attempted to suppress and discredit protestors seeking
democratic reforms in Sudan,” or enabled Prigozhin to evade U.S. sanctions.41
In April 2021, OFAC imposed sanctions on 24 additional Prigozhin-linked individuals and
entities for facilitating global influence operations, including in Africa and Europe, evading
sanctions, and helping IRA personnel commit identity fraud.
Other Malicious Cyber-Enabled and Intelligence Activities
OFAC has designated individuals and entities for malicious Russian cyber-enabled and
intelligence activities unrelated to election interference. Pursuant to Section 224, OFAC
designated in March 2018 the FSB, GRU, and four GRU officers (all previously designated under
E.O. 13694, as amended, for U.S. election interference), as well as two other GRU officers, for

38 U.S. Department of the Treasury, “Treasury Sanctions Russia-linked Election Interference Actors,” press release,
September 10, 2021.
39 U.S. Department of the Treasury, “Treasury Takes Further Action Against Russian-linked Actors,” press release,
January 11, 2021.
40 U.S. Department of the Treasury, “Treasury Escalates Sanctions Against the Russian Government’s Attempts to
Influence U.S. Elections,” press release, April 15, 2021.
41 U.S. Department of the Treasury, “Treasury Targets Financier’s Illicit Sanctions Evasion Activity,” July 15, 2020;
and U.S. Department of the Treasury, “Treasury Increases Pressure on Russian Financier,” September 23, 2020.
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“destructive cyberattacks.” These cyberattacks included the 2017 “NotPetya” ransomware attack
the Treasury Department called “the most destructive and costly cyberattack in history.”42 In
December 2018, OFAC designated four more GRU officers for cyber operations against the
World Anti-Doping Agency and/or the Organization for the Prohibition of Chemical Weapons
(OPCW). These officers have been indicted by the Department of Justice for related crimes.43
OFAC has designated individuals and entities for facilitating intelligence activities and sanctions
evasion for the FSB and other Russian intelligence services. In June and August 2018, OFAC
designated under E.O. 13694, as amended, five individuals and seven entities the Treasury
Department referred to as FSB enablers. One of these entities, Divetechnoservices, “procured a
variety of underwater equipment and diving systems for Russian government agencies” and “was
awarded a contract to procure a submersible craft.” The Treasury Department noted that Russia
“has been active in tracking undersea communications cables, which carry the bulk of the world’s
telecommunications data.”44 In September 2020, OFAC designated one company and four related
individuals and entities for conducting related trade with Divetechnoservices, another underwater
technology company, and four related individuals.
In October 2020, OFAC designated a Russian government research institution for allegedly
supporting a Triton malware attack that targets industrial safety systems and “has been deployed
against U.S. partners in the Middle East.”45
In April 2021, under the new E.O. 14024, OFAC designated six Russian technology companies
for supporting the GRU, SVR, and FSB. In announcing the sanctions, the Treasury Department
said Russia’s intelligence services “have executed some of the most dangerous and disruptive
cyber attacks in recent history, including the SolarWinds cyber attack [that compromised victims
in] the financial sector, critical infrastructure, government networks, and many others.”46
OFAC has designated Russian individuals and entities for financial cybercrimes. In December
2019, OFAC designated a Russian cybercriminal organization known as Evil Corp and 23 related
individuals and entities under E.O. 13694, as amended. The Treasury Department alleged that
Evil Corp deployed malware “to infect computers and harvest login credentials from hundreds of
banks and financial institutions in over 40 countries, causing more than $100 million in theft.”47
The same day, the Department of Justice announced related charges against two alleged leaders of
Evil Corp.

42 U.S. Department of the Treasury, “Treasury Sanctions Russian Cyber Actors for Interference with the 2016 U.S.
Elections and Malicious Cyber-Attacks,” press release, March 15, 2018. On the NotPetya attack, see Andy Greenberg,
“The Untold Story of NotPetya, The Most Devastating Cyberattack in History,” Wired, August 22, 2018.
43 U.S. Department of Justice, “U.S. Charges Russian GRU Officers with International Hacking and Related Influence
and Disinformation Operations,” press release, October 4, 2018.
44 U.S. Department of the Treasury, “Treasury Sanctions Russian Federal Security Service Enablers,” press release,
June 11, 2018. Also see Greg Walters, “The U.S. Is Worried About Russian Submarines Spying on the Internet,” Vice
News
, June 11, 2018.
45 U.S. Department of the Treasury, “Treasury Sanctions Russian Government Research Institution Connected to the
Triton Malware,” press release, October 23, 2020.
46 U.S. Department of the Treasury, “Treasury Sanctions Russia with Sweeping New Sanctions Authority,” press
release, April 15, 2021.
47 Three associated entities that OFAC designated were delisted eight days later. U.S. Department of the Treasury,
“Treasury Sanctions Evil Corp, the Russia-Based Cybercriminal Group Behind Dridex Malware,” press release,
December 5, 2019; and Meduza, “U.S. Treasury Removes Three Russian Companies with Alleged Ties to Hacker
Collective Evil Corp from Sanctions List,” December 13, 2019.
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OFAC has imposed cybercrime-related sanctions on two individuals for illicit financial-related
activities (in December 2016), two individuals for involvement in a scheme targeting holders of
virtual currency assets (September 2020), a virtual currency exchange (the first such entity to be
designated by OFAC) for “facilitating financial transactions for ransomware actors” (September
2021), and related ransomware actors (November 2021).48
Arms Sales
Also in response to malicious cyber-enabled activities, the U.S. government has imposed
secondary sanctions pursuant to Section 231 of CRIEEA, targeting those engaged in “significant
transactions” with the Russian defense or intelligence sectors, including arms sales.
In October 2017, the State Department issued initial guidance regarding its implementation of
Section 231 sanctions. It indicated it would examine “a wide range of factors ... in looking at any
individual case” to determine whether a “significant transaction” had occurred. These factors
“may include, but are not limited to, the significance of the transaction to U.S. national security
and foreign policy interests, in particular whether it has a significant adverse impact on such
interests; the nature and magnitude of the transaction; and the relation and significance of the
transaction to the defense or intelligence sector of the Russian government.”49 In August 2018,
then-U.S. Assistant Secretary of State Wess Mitchell said the threat of Section 231 sanctions had
led to some $8-$10 billion in “foreclosed arms deals.”50
OFAC has imposed Section 231 sanctions in response to significant arms purchases by two
countries, China and Turkey. In September 2018, OFAC designated the Equipment Development
Department of China’s Central Military Commission, as well as its director, for taking delivery of
10 Su-35 combat aircraft in December 2017 and S-400 surface-to-air missile system-related
equipment in 2018. In December 2020, OFAC designated Turkey’s Presidency of Defense
Industries, its head, and related officers for taking delivery of S-400 surface-to-air missile system-
related equipment.51
CRIEEA grants the President authority to waive the application of sanctions for national security
reasons, but this waiver is subject to congressional review under Section 216 of the act. As
originally enacted, Section 231 authorized the President to waive the initial application of
sanctions for national security reasons or to “further the enforcement of this title,” but only if the
President certified that Russia had “made significant efforts to reduce the number and intensity of
cyber intrusions.” In addition, the President could delay the imposition of sanctions, if the
President certified that an individual or entity was “substantially reducing the number of
significant transactions” it makes with Russia’s defense or intelligence sector.

48 U.S. Department of the Treasury, “Treasury Takes Robust Actions to Counter Ransomware,” press release,
September 21, 2021.
49 U.S. Department of State, “Briefing on Sanctions with Respect to Russia’s Defense and Intelligence Sectors Under
Section 231 of the Countering America’s Adversaries Through Sanctions Act of 2017,” October 27, 2017; and U.S.
Department of State, “Public Guidance on Sanctions with Respect to Russia’s Defense and Intelligence Sectors Under
Section 231 of the Countering America’s Adversaries Through Sanctions Act of 2017,” updated September 20, 2018.
50 Testimony of A. Wess Mitchell, in U.S. Congress, Senate Committee on Foreign Relations, U.S.-Russia Relations,
hearings, 115th Cong., 2nd sess., August 21, 2018, transcript at http://www.cq.com/doc/congressionaltranscripts-
5378064.
51 In both cases, the Secretary of State, in consultation with the Secretary of the Treasury, selected five specific
sanctions, pursuant to CRIEEA, to impose on the two defense agencies. Section 231 of CRIEEA requires the President
to impose at least 5 of 12 sanctions described in Section 235 on individuals and entities that the President determines
have engaged in significant transactions with Russia’s defense or intelligence sector.
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Congress amended Section 231 in the John S. McCain National Defense Authorization Act for
Fiscal Year 2019 (P.L. 115-232, §1294). The amendment provides for a national security waiver
that does not require congressional review but does require the President to certify a transaction
would not (1) be with an entity that directly participated in or facilitated cyber intrusions, (2)
endanger the United States’ multilateral alliances or ongoing operations, (3) increase the risk of
compromising U.S. defense systems, or (4) negatively impact defense cooperation with the
country in question. The President also must certify that the country is taking steps to reduce the
share of Russian-produced arms and equipment in its total inventory or is cooperating with the
United States on other matters critical to U.S. national security.
In addition, the executive branch fulfills a Section 231 reporting requirement to “specify the
persons that are part of, or operate for or on behalf of, [Russia’s] defense and intelligence
sectors.”52 The State Department initially stated that the entities on the list were not subject to
sanctions but that secondary sanctions could be imposed on individuals and entities “that are
determined to knowingly engage in a significant transaction with a person specified in the
Guidance on or after the date of enactment of the Act.”53 The State Department expanded and
formalized the list as the List of Specified Persons in September 2018; in doing so, the State
Department indicated that “any person who knowingly engages in a significant transaction with
any of these persons is subject to mandatory sanctions under [CRIEEA] section 231.”54
Countering Russian Influence in Europe and Eurasia Act of 2017
On August 2, 2017, President Trump signed the Countering America’s Adversaries Through Sanctions Act of 2017
(CAATSA, P.L. 115-44), which includes as Title II the Countering Russian Influence in Europe and Eurasia Act of
2017 (CRIEEA, 22 U.S.C. 9501 et seq.). CRIEEA codifies Ukraine-related and cyber-related E.O.s (discussed
above), strengthens sanctions authorities initiated in Ukraine-related E.O.s and legislation, and identifies several
new sanctions targets. It also establishes congressional review of any action the President takes to ease or lift a
variety of sanctions imposed on Russia. In September 2018, President Trump issued E.O. 13849 establishing the
means to implement certain sanctions provided for in CRIEEA (and the Ukraine Freedom Support Act of 2014, as
amended [UFSA; P.L. 113-272; 22 U.S.C. 8921 et seq.]).
As of January 2022, OFAC has issued 44 designations based on new sanctions authorities in CRIEEA, relating to
undermining cybersecurity and/or affiliation with Russian intelligence services subject to U.S. sanctions (§224, 32
designations), human rights abuses (§228, amending SSIDES, 3 designations), arms sales (§231, 7 designations), and
export pipeline development (§232, 2 designations). These designations are discussed in the relevant sections of
this report.
Some Members of Congress have called on the President to make more designations based on CRIEEA’s
mandatory sanctions provisions. As of January 2022, OFAC has not issued designations under other CRIEEA
authorities. The Administration could use these authorities to target the fol owing:

Significant foreign investment in deepwater, Arctic offshore, or shale oil projects within Russia (§225,
amending UFSA);

Foreign financial institutions that facilitate certain transactions for Russia’s defense or energy sectors, or for
those subject to sanctions related to Russia’s invasion of Ukraine (§226, amending UFSA);

Those who engage in significant corruption (§227, amending UFSA);

Sanctions evaders and foreign persons that facilitate significant transactions for those subject to sanctions on
Russia (§228, amending SSIDES);

52 U.S. Department of State, “CAATSA Section 231(e) Defense and Intelligence Sectors of the Government of the
Russian Federation,” updated March 2, 2021.
53 U.S. Department of State, “Public Guidance on Sanctions with Respect to Russia’s Defense and Intelligence Sectors
Under Section 231 of the Countering America’s Adversaries Through Sanctions Act of 2017,” updated September 20,
2018.
54 U.S. Department of State, “CAATSA Section 231: ‘Addition of 33 Entities and Individuals to the List of Specified
Persons and Imposition of Sanctions on the Equipment Development Department,’” September 20, 2018.
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Investment (or facilitating investment) that contributes to the privatization of Russia’s state-owned assets “in
a manner that unjustly benefits” government officials and associates (§233); and

Any foreign person who supports or facilitates Syria’s acquiring or developing a variety of advanced or
prohibited weapons and defense articles, including weapons of mass destruction (§234).

Source: E.O. 13849 of September 20, 2018, “Authorizing the Implementation of Certain Sanctions Set Forth in
the Countering America’s Adversaries Through Sanctions Act,” 83 Federal Register 48195.
Use of a Chemical Weapon
CBW Act Sanctions
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.) provides for sanctions against the government of a
foreign country that the Secretary of State determines has used a chemical weapon in
contravention of international law or against its own nationals.
When such a finding is made, the CBW Act first requires the President (delegating authority to
the Secretary of State) to, forthwith,
 Terminate foreign assistance other than that which addresses urgent humanitarian
situations or provides food or other agricultural products;
 Terminate arms sales;
 Terminate export licenses for U.S. Munitions List items;
 Terminate foreign military financing;
 Deny credit, credit guarantees, or other financial assistance from the U.S.
government, including Export-Import Bank programs; and
 Deny export licenses for goods or technology controlled for national security
reasons (the Commodity Control List).55
Within three months after the initial determination, the CBW Act requires the President to impose
at least three additional restrictions unless he determines and certifies to Congress that the
government in question
 “Is no longer using chemical or biological weapons in violation of international
law or using lethal chemical or biological weapons against its own nationals”;
 “Has provided reliable assurances that it will not in the future engage in any such
activities”; and
 “Is willing to allow on-site inspections by United Nations observers or other
internationally recognized, impartial observers, or other reliable means exist, to
ensure that that government is not using chemical or biological weapons in

55 CBW Act, §307(a); 22 U.S.C. 5605(a). President Clinton delegated the authority to make determinations and
exercise waiver authority to the Secretary of State. Based on the Secretary of State’s determinations, the authority to
restrict certain imports or exports is delegated to, respectively, the Secretary of the Treasury and the Secretary of
Commerce. Executive Order 12851 of June 11, 1993, “Administration of Proliferation Sanctions, Middle East Arms
Control, and Related Congressional Reporting Responsibilities,” 58 Federal Register 33181.
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violation of international law and is not using lethal chemical or biological
weapons against its own nationals.... ”56
The CBW Act’s menu of possible second-round sanctions includes the authority to
 Oppose loans or financial or technical assistance by international financial
institutions;
 Prohibit U.S. banks from making loans or providing credit to the violating
government, except for the purchase of food or other agricultural products;
 Prohibit exports of other goods and technology, except food and other
agricultural products;
 Restrict importation into the United States of articles that are the growth, product,
or manufacture of the violating government;
 Downgrade or suspend diplomatic relations; and
 set in motion the suspension of foreign air carriers owned or controlled by the
violating government “to engage in foreign air transportation to or from the
United States.”57
The CBW Act authorizes the President to waive sanctions if the President finds it essential to U.S.
national security interests and notifies Congress at least 15 days in advance. The President also
may waive sanctions if the President finds that the violating government has undergone
fundamental changes in leadership or policies (and notifies Congress at least 20 days in
advance).58
CBW-related sanctions remain in place for at least a year. The sanctions may be removed only
after the President determines and certifies to Congress that the three conditions stated above
have been met and that the violating government is making restitution to those affected by the use
of the chemical weapon.
Poisoning of Sergei Skripal
On August 6, 2018, then-Secretary of State Michael Pompeo determined that in March 2018, the
Russian government used a chemical weapon in the UK in contravention of international law. The
primary victims were British citizen Sergei Skripal, a former Russian military intelligence officer
once imprisoned in Russia for allegedly working as a UK double agent, and his daughter. This
finding triggered the CBW Act.59 Russian authorities denied involvement in the attack or
possession of chemical weapons.
On August 27, 2018, the State Department announced the imposition of a first round of CBW Act
sanctions but invoked national security waiver authority to allow for the continuation of
 Foreign assistance;

56 CBW Act, §307(b)(1); 22 U.S.C. 5605(b)(1).
57 CBW Act, §307(b)(2); 22 U.S.C. 5605(b)(2).
58 CBW Act, §307(d)(1)(B); 22 U.S.C. 5605(d)(1)(B).
59 The CBW Act has been invoked on two other occasions. In 2013, the State Department determined that the
government of Syria had used chemical weapons but for national security reasons sanctions decisions would be applied
on a case-by-case basis. In 2018, the Secretary of State determined that the government of North Korea was responsible
for a lethal 2017 nerve agent attack on the half-brother of North Korean leader Kim Jong-un, in Malaysia. Sanctions
imposed were largely redundant with restrictions already in place.
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 Exports related to space cooperation and commercial space launches; and
 Export licensing for specific categories of national security-sensitive goods and
technology, including exports related to civil aviation safety, commercial end-
users civil end-uses, wholly owned U.S. and other foreign subsidiaries operating
in Russia, and deemed export licenses for Russian nationals working in the
United States.60
On November 6, 2018, the State Department informed Congress that it “could not certify that
Russia met the required conditions” and intended “to proceed in accordance with the terms of the
CBW Act, which directs the implementation of additional sanctions.”61 The Administration did
not immediately impose a second round of CBW Act-related sanctions, but in December 2018
OFAC imposed sanctions on two GRU officers for the “attempted assassination” of Skripal and
his daughter through the use of a lethal nerve agent.62
The Administration took its next steps to implement CBW Act-related sanctions in August 2019.
On August 1, President Trump issued E.O. 13883 to require the Secretary of the Treasury to
implement measures, “when necessary,” to oppose U.S. support for international financing and to
prohibit access to U.S. bank loans.63 On August 2, Treasury issued a directive (the “CBW Act
Directive”) specifying that the latter measures prohibited U.S. banks from “lending non-ruble
denominated funds to the Russian sovereign” or participating “in the primary market for non-
ruble denominated bonds issued by the Russian sovereign” (such restrictions were expanded to
ruble-denominated funds in 2021; see “Poisoning of Alexei Navalny,” below).64 According to
Treasury, U.S. banks are not prohibited from participating in the secondary market for Russian
sovereign debt. Prohibitions do not apply to transactions with Russian state-owned enterprises. In
addition, export licenses to Russian state-owned or state-funded enterprises for goods controlled
for their dual-use chemical and biological applications became subject to a “presumption of
denial” policy.65
Poisoning of Alexei Navalny
On March 2, 2021, Secretary of State Antony Blinken determined that in August 2020, the
Russian government used a chemical weapon against its own national, Russian opposition figure
Alexei Navalny. This finding again triggered the CBW Act. The Department of State called the
attack an “attempted assassination,” and the White House stated that the intelligence community

60 U.S. Department of State, “Determinations Regarding Use of Chemical Weapons by Russia Under the Chemical and
Biological Weapons Control and Warfare Elimination Act of 1991,” 83 Federal Register 43723, August 27, 2018.
61 Reuters, “U.S. Intends More Sanctions On Russia Over Chemical Weapons: Spokeswoman,” November 6, 2018.
62 Although the attempted assassination was not cyber-related, OFAC used CRIEEA, Section 224 (undermining
cybersecurity), to designate these officers as agents of the previously designated GRU. U.S. Department of the
Treasury, “Treasury Targets Russian Operatives over Election Interference, World Anti-Doping Agency Hacking, and
Other Malign Activities,” press release, December 19, 2018.
63 E.O. 13883 of August 1, 2019, “Administration of Proliferation Sanctions and Amendment of Executive Order
12851,” 84 Federal Register 38113.
64 Office of Foreign Assets Control, “Issuance of Russia-Related Directive Pursuant to Executive Order 13883 of
August 1, 2019,” 84 Federal Register 48704, September 16, 2019.
65 U.S. Department of State, “Imposition of Additional Sanctions on Russia Under the Chemical and Biological
Weapons Control and Warfare Elimination Act of 1991,”84 Federal Register 44671, August 26, 2019.
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assessed with “high confidence” that officers of the FSB were responsible for the attack. Russian
authorities denied involvement.66
Secretary Blinken announced the imposition of the first round of sanctions but invoked national
security waiver authority to allow for the continuation of
 Foreign assistance;
 Exports related to space cooperation and, until September 1, 2021, commercial
space launches; and
 Export licensing for specific categories of national security-sensitive goods and
technology, including exports related to civil aviation safety, wholly owned U.S.
and other foreign subsidiaries operating in Russia, and deemed export licenses.67
In addition, the Department of State added Russia to the International Trafficking in Arms
Regulations list of countries subject to a policy of denial for exports of defense articles and
services.68
The Department of State also imposed sanctions on the FSB, GRU, two GRU officers, and three
research institutes for use of a chemical weapon in either the 2020 attack or the 2018 attack
against Skripal (the FSB, GRU, and GRU officers were already subject to U.S. sanctions). These
sanctions were imposed pursuant to E.O. 13382, targeting proliferators of weapons of mass
destruction and their supporters.69
Simultaneously, the Treasury Department imposed sanctions on seven Russian government
officials, including the FSB director and Russia’s prosecutor general, for Navalny’s poisoning
and subsequent imprisonment. These sanctions were imposed pursuant to E.O. 13661 (issued in
response to Russia’s invasion of Ukraine but targeting Russian government officials) and, in the
case of the FSB director, also E.O. 13361. The sanctions were imposed in coordination with the
EU, which imposed an initial round of sanctions in October 2020.
On August 20, 2021, the State Department and the Treasury Department announced a second
round of CBW Act sanctions and additional measures.70 These measures again included U.S.
opposition to the provision of international loans or assistance to the Russian government, a
prohibition against U.S. bank loans to the Russian government in non-ruble denominated funds,
and a prohibition against U.S. bank participation in the primary market for non-ruble
denominated sovereign bonds. Measures also included a “presumption of denial” policy on U.S.
exports to Russia of nuclear, chemical, biological, and missile-related goods and technology, as
well as a prohibition on the permanent importation of firearms and ammunition, as defined on the
U.S. Munitions Import List, that are manufactured or located in Russia.

66 U.S. Department of State, “Imposing Sanctions on Russia for the Poisoning and Imprisonment of Aleksey Navalny,”
March 2, 2021; and White House, “Press Briefing by Press Secretary Jen Psaki,” March 2, 2021.
67 U.S. Department of State, “Imposition of Additional Sanctions on Russia Under the Chemical and Biological
Weapons Control and Warfare Elimination Act of 1991,” 86 Federal Register 24804, March 18, 2021.
68 U.S. Department of State, “International Traffic in Arms Regulations: Addition of Russia,” 86 Federal Register
14802, March 18, 2021.
69 Executive Order 13382 of June 28, 2005, “Blocking Property of Weapons of Mass Destruction Proliferators and
Their Supporters,” 70 Federal Register 38567.
70 U.S. Department of State, “Imposition of Additional Sanctions on Russia Under the Chemical and Biological
Weapons Control and Warfare Elimination Act of 1991,” 86 Federal Register 50203, September 7, 2021.
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The Treasury Department or the State Department also imposed sanctions on nine Russian
individuals (mostly FSB officers) and four Russian entities (two already subject to sanctions)
involved in Navalny’s poisoning or Russia’s chemical weapons program. These sanctions were
imposed pursuant to E.O. 13382 or E.O. 14024 (on Russian harmful foreign activities).
Separately, under E.O. 14024, and an accompanying directive, the Biden Administration in April
2021 expanded the Trump Administration’s prohibition against U.S. financial institutions
participating in the primary market for Russian sovereign bonds or lending to the Russian
government to include ruble-denominated funds.71
Human Rights Abuses and Corruption
Sanctions Authorities
In December 2012, Congress passed and the President signed into law the Sergei Magnitsky Rule
of Law Accountability Act of 2012 (hereinafter the Sergei Magnitsky Act).72 This legislation
bears the name of Sergei Magnitsky, a Russian lawyer and auditor who died in prison in
November 2009 after uncovering massive tax fraud that allegedly implicated government
officials. The act entered into law as part of a broader piece of legislation related to U.S.-Russia
trade relations (see text box entitled “Linking U.S.-Russia Trade to Human Rights,” below).
The Sergei Magnitsky Act requires the President to impose sanctions on those he identifies as
having been involved in the “criminal conspiracy” that Magnitsky uncovered and in his
subsequent detention, abuse, and death.73 The act also requires the President to impose sanctions
on those he finds have committed gross violations of internationally recognized human rights
against individuals fighting to expose the illegal activity of Russian government officials or
seeking to exercise or defend human rights and freedoms.
Subsequently, in December 2016, the Global Magnitsky Human Rights Accountability Act (P.L.
114-328, Title XII, Subtitle F; 22 U.S.C. 2656 note) was enacted.74 This act authorizes the
President to apply globally the human rights sanctions authorities aimed at the treatment of
whistleblowers and human rights defenders that were originally set out in the Sergei Magnitsky
Act. The Global Magnitsky Act also authorizes the President to impose sanctions against
government officials and associates around the world responsible for acts of significant
corruption.
In December 2017, President Trump issued E.O. 13818 to implement the Global Magnitsky Act,
in the process expanding the target for sanctions to include those who commit any “serious
human rights abuse” around the world, not just gross human rights violations against
whistleblowers and human rights defenders.75

71 Office of Foreign Assets Control, “Publication of Russian Harmful Foreign Activities Directive 1,” 86 Federal
Register
35867, July 7, 2021.
72 The act was enacted as Title IV of the Russia and Moldova Jackson-Vanik Repeal and Sergei Magnitsky Rule of
Law Accountability Act of 2012 (P.L. 112-208). “Jackson-Vanik” refers to provisions in the Trade Act of 1974 that
conditioned U.S. trade with the Soviet Union on that country’s emigration policies (P.L. 93-618, §402; formerly 19
U.S.C. 2432) (see text box entitled “Linking U.S.-Russia Trade to Human Rights”).
73 Sergei Magnitsky Act, §404(a)(1); 22 U.S.C. 5811 note.
74 For more, see CRS In Focus IF10576, The Global Magnitsky Human Rights Accountability Act, by Michael A.
Weber and Edward J. Collins-Chase.
75 Executive Order 13818 of December 20, 2017, “Blocking the Property of Persons Involved in Serious Human Rights
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SSIDES, as amended by CRIEEA in 2017, provides for sanctions on those responsible for “the
commission of serious human rights abuses in any territory forcibly occupied or otherwise
controlled” by the Russian government, as well as on Russian government officials and associates
responsible for acts of significant corruption worldwide.76
In FY2008, Congress began including a requirement in annual State Department and Foreign
Operations Appropriations Acts (referred to as Section 7031(c) authorities) that the Secretary of
State shall deny entry into the United States of certain foreign officials involved in the corrupt
extraction of natural resources. This provision gradually was broadened and now requires the
denial of entry of foreign government officials and their immediate family members for whom
there is credible information that the individual has been involved, “directly or indirectly, in
significant corruption […] or a gross violation of human rights.”77
Related Actions
As of January 2022, OFAC has designated 54 individuals and one entity pursuant to the Sergei
Magnitsky Act. Forty designees are directly associated with the alleged crimes that Magnitsky
uncovered or his subsequent ill-treatment and death. OFAC also has designated 11 individuals
and one entity for human rights violations and killings in Russia’s Chechen Republic or for the
2004 killing of Paul Klebnikov, the American chief editor of the Russian edition of Forbes.78 Two
designations target the suspected killers of former Russian spy Alexander Litvinenko in London
in 2006.79 Another designation targets an overseer of prison abuse in Russia’s Karelia region.
Under the Global Magnitsky Act, OFAC has designated at least 14 Russian nationals.80 Among
the first round of designations was the son of Russia’s then-prosecutor general, who was cited for
alleged involvement in high-level corruption.81 Subsequently, OFAC designated the head of
Russia’s Chechen Republic and 11 related individuals and entities for serious human rights
abuses.

Abuse or Corruption,” 82 Federal Register 60839. E.O. 13818 must be extended annually to remain in force; the
President extended it most recently on December 16, 2021.
76 P.L. 115-44, §228; 22 U.S.C. 8910.
77 Most recently, Section 7031(c) of the Department of State, Foreign Operations, and Related Programs
Appropriations Act, 2020 (Division G, P.L. 116-94, Further Continuing Appropriations Act, 2020). Section 7031(c)(3)
authorizes the Secretary of State to waive designating an individual if he determines “that the waiver would serve a
compelling national interest or that the circumstances which caused the individual to be ineligible [to enter the United
States] have changed sufficiently.” The act provides for private designations as well; designations are to be reported
regularly to the Foreign Relations/Affairs, Appropriations, and Judiciary Committees. For more, see CRS In Focus
IF10905, FY2020 Foreign Operations Appropriations: Targeting Foreign Corruption and Human Rights Violations,
by Liana W. Rosen and Michael A. Weber.
78 On the killing of Paul Klebnikov, see Otto Pohl, “The Assassination of a Dream,” New York, November 2004;
Richard Behar, “Open Letter to Russia’s Putin on Tenth Anniversary of Forbes’ Editor Paul Klebnikov’s Murder: Why
Haven’t You Solved It?,” Forbes, July 16, 2014; and Bermet Talant, “American Journalist Paul Klebnikov’s Alleged
Killer Arrested in Kyiv,” Kyiv Post, November 19, 2017.
79 On the killing of Alexander Litvinenko, see Alex Goldfarb with Marina Litvinenko, Death of a Dissident: The
Poisoning of Alexander Litvinenko and the Return of the KGB
(New York: Free Press, 2007); and Luke Harding, A
Very Expensive Poison: The Assassination of Alexander Litvinenko and Putin’s War with the West
(New York: Vintage
Books, 2017).
80 In all, 146 individuals and 189 affiliated entities currently are designated pursuant to the Global Magnitsky Act.
81 Treasury also has designated under the Global Magnitsky Act a former Ukrainian special police force commander
with dual Ukrainian-Russian citizenship; he was designated for violence against protestors in Ukraine.
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In 2018, President Trump cited SSIDES, as amended by CRIEEA, Section 228, to designate two
individuals and one entity for committing serious human rights abuses in territories forcibly
occupied or controlled by Russia.
Under Section 7031(c) authorities, the State Department has publicly designated for human rights
abuses at least nine Russian nationals: the head of Russia’s Chechen Republic, his spouse, and
two children; another senior official from the Chechen Republic, his spouse, and another Chechen
official; and two regional officials for their alleged involvement “in torture and/or cruel, inhuman,
or degrading treatment or punishment” of Jehovah’s Witnesses.82
Linking U.S.-Russia Trade to Human Rights
The Sergei Magnitsky Rule of Law Accountability Act of 2012 (Sergei Magnitsky Act; P.L. 112-208, Title IV; 22
U.S.C. 5811 note) continues a U.S. foreign policy tradition that links U.S. trade with Russia to concerns about
human rights. The act is part of a broader piece of legislation granting permanent normal trade relations (PNTR)
status to Russia. This legislation authorized the President to terminate the application to Russia of Title IV of the
Trade Act of 1974 (P.L. 93-618; 19 U.S.C. 2101 et seq.), pursuant to which Russia was denied PNTR status. The
Trade Act originally imposed restrictions on trade with Russia’s predecessor, the Soviet Union, due to its
nonmarket economy and prohibitive emigration policies (the latter through Section 402, popularly cited as the
Jackson-Vanik amendment). After the col apse of the Soviet Union, these trade restrictions formally continued to
apply to Russia, even though the United States granted Russia conditional normal trade relations beginning in 1992.
In 2012, Russia joined the World Trade Organization (WTO), with U.S. support. The United States subsequently
had to grant Russia PNTR status or opt out of WTO “obligations, rules, and mechanisms” with respect to Russia
(H.Rept. 112-632). Although the PNTR legislation enjoyed broad congressional support, some Members of
Congress were reluctant to terminate the application to Russia of the Trade Act’s Jackson-Vanik amendment,
which helped champion the cause of Soviet Jewish emigration in the 1970s, without replacing it with new human
rights legislation. According to one of the original Senate sponsors of the Sergei Magnitsky Act, Senator Benjamin
Cardin, pairing the Sergei Magnitsky Act with the PNTR legislation “allowed us to get this human rights tool
enacted” while “[giving] us the best chance to get the PNTR bil done in the right form.” He elaborated, “today we
close a chapter in the U.S. history on the advancing of human rights with the repeal ... of Jackson-Vanik. It served
its purpose. Today, we open a new chapter in U.S. leadership for human rights with the Sergei Magnitsky Rule of
Law Accountability Act” (Congressional Record, S7437, December 5, 2012).
Section 241 “Oligarch” List and Related Sanctions
CRIEEA, in Section 241, requires the Administration to submit a report to Congress that includes
“an identification of any indices of corruption” among “the most significant senior foreign
political figures and oligarchs in the Russian Federation, as determined by their closeness to the
Russian regime and their net worth.” The Section 241 requirement neither authorizes nor requires
the President to impose sanctions on individuals included in the report.
The Treasury Department submitted this report in unclassified form with a classified annex in
January 2018. The unclassified report drew on publicly available lists of political figures and
wealthy Russians, without assessments of their closeness to the regime or “indices of
corruption.”83 According to the Treasury Department, the classified annex contains an “extremely
thorough analysis” of information pertaining, among other things, to “links to corruption, and
international business affiliations of the named Russian persons.”84

82 U.S. Department of State, “Public Designation Due to Involvement in Gross Violations of Human Rights of Vladimir
Yermolayev and Stepan Tkach, Officials of the Investigative Committee in the Russian Federation,” September 10,
2019.
83 U.S. Department of the Treasury, “Treasury Releases CAATSA Reports, Including on Senior Foreign Political
Figures and Oligarchs in the Russian Federation,” press release, January 29, 2018.
84 U.S. Department of the Treasury, “Treasury Information on CAATSA Report and Russian Sanctions,” press release,
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Many observers speculated that the list—or a more tailored version, possibly based on
information from the classified annex—could serve as the basis for new sanctions designations.
In January 2018 testimony to the Senate Committee on Banking, Housing, and Urban Affairs,
then-Secretary of the Treasury Steven Mnuchin indicated that “we intend to now use that report
and that intelligence to go forward with additional sanctions.”85
On April 6, 2018, OFAC designated several politically connected Russian billionaires (whom the
Treasury Department referred to as oligarchs), companies owned or controlled by these
individuals, and government officials. OFAC made these designations under Ukraine-related
emergency authorities codified by CRIEEA. The Treasury Department implied the designations
were in the spirit of CRIEEA’s broader authorities, as they were “in response to worldwide
malign activity” and not just Russia’s invasion of Ukraine.86 The Treasury Department added,
“Russian oligarchs and elites who profit from [a] corrupt system will no longer be insulated from
the consequences of their government’s destabilizing activities.”
In particular, the designation of Rusal, a leading global producer of aluminum, attracted
international attention. The move marked the first time OFAC designated one of Russia’s top
companies. International attention also focused on the fact that designating Rusal could lead to
the possible imposition of wide-ranging secondary sanctions, mandated by CRIEEA, on foreign
individuals and entities that facilitate significant transactions on behalf of designees. Rusal’s
designation made foreign banks and firms reluctant to engage in transactions with the firm.
The Trump Administration appeared to be responsive to international concerns regarding Rusal’s
designation. In April 2018, the Administration provided a six-month wind-down period for
transactions with Rusal that it repeatedly prolonged. In addition, Treasury officials indicated the
United States would remove sanctions against the firm if Kremlin-connected billionaire Oleg
Deripaska, who is subject to sanctions, divested and ceded control (since his control was the
justification for Rusal’s designation in the first place). In December 2018, the Treasury
Department announced that an agreement on eliminating Deripaska’s control of Rusal’s parent
company had been reached and, accordingly, notified Congress it intended to terminate sanctions
on Rusal and two related companies in 30 days.87
The Russia Sanctions Review Act of 2017 (Part 1 of CRIEEA; 22 U.S.C. 9511) provides a means
for Congress to block the President’s action to terminate or waive certain sanctions on Russia if
Congress adopts a (presumably) veto-proof joint resolution of disapproval within 30 days of the
President taking the action. In January 2019, the Senate and House each took up the matter. The
House adopted H.J.Res. 30 to disapprove the delisting of Rusal by a vote of 362-53; the Senate

February 1, 2018.
85 Testimony of Steven Mnuchin, in U.S. Congress, Senate Committee on Banking, Housing, and Urban Affairs,
Hearing on Financial Stability Oversight Council Annual Report, 114th Cong., 2nd sess., January 30, 2018, transcript at
http://www.cq.com/doc/congressionaltranscripts-5256410?17.
86 OFAC made the designations one month after the March 4, 2018, nerve agent attack against UK citizen and former
Russian intelligence officer Sergei Skripal and his daughter in the United Kingdom (see “Use of a Chemical Weapon”)
and one week after the Administration responded to that attack by expelling 60 Russian diplomats it said were
intelligence operatives and closing Russia’s Consulate General in Seattle. U.S. Department of the Treasury, “Treasury
Designates Russian Oligarchs, Officials, and Entities in Response to Worldwide Malign Activity,” press release, April
6, 2018.
87 U.S. Department of the Treasury, “OFAC Notifies Congress of Intent to Delist EN+, Rusal, and EuroSibEnergo,”
press release, December 19, 2018; and RFE/RL, “Rusal Names New Chairman as Part of Deal to End U.S. Sanctions,”
December 28, 2018.
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failed to invoke cloture for final consideration of its companion bill, S.J.Res. 2, by a vote of 57-
42.
Nord Stream 2: Energy Exports as a Coercive or Political Tool
Three legislative authorities have established sanctions related to the use of Russian energy
exports as a coercive or political tool. Two of these authorities have been used to target Russia’s
Nord Stream 2 natural gas pipeline to Germany.88 Russian state-owned energy company Gazprom
owns the Nord Stream 2 pipeline. Reportedly, about half the cost is financed by five European
companies in agreements concluded prior to the enactment of these authorities.
Construction of the Nord Stream 2 pipeline was initially suspended in December 2019, after
Congress passed legislation establishing a new round of sanctions related to the pipeline.
Construction resumed at the end of 2020 and reportedly was completed in September 2021.
Additional steps, including certification by German authorities, are required before the pipeline
will be able to transport gas.89
The first related authority is UFSA, Section 4(b)(3), which authorizes sanctions on Gazprom if
the President determines Gazprom is withholding significant natural gas supplies from NATO
member states or countries such as Ukraine, Georgia, and Moldova. No sanctions have been
imposed under this authority.
The second related authority is CRIEEA, Section 232, which authorizes (but does not require)
sanctions on those who invest at least $1 million (or $5 million over 12 months) or provide
goods, services, or support valued at the same amount for the construction of Russian energy
export pipelines, including Nord Stream 2. On President Trump’s last full day in office, the
Trump Administration imposed sanctions on Russian vessel Fortuna, which Gazprom was using
to complete construction of Nord Stream 2, and its corporate owner, pursuant to Section 232.
A third related authority is the Protecting Europe’s Energy Security Act of 2019, as amended
(PEESA). PEESA was enacted on December 20, 2019, as part of the FY2020 National Defense
Authorization Act (P.L. 116-92, Title LXXV). In January 2021, Congress amended PEESA to
clarify and expand its pipeline-related sanctions (P.L. 116-283, §1242). In August 2021, President
Biden issued E.O. 14039, establishing the means to implement certain sanctions provided for in
PEESA.90
PEESA, as amended, establishes sanctions on foreign persons whom the President determines
have sold, leased, provided, or facilitated the provision of vessels for the purpose of subsea pipe-
laying activities related to the construction of Nord Stream 2 and TurkStream (a second new
Russian gas export pipeline) or any successor pipeline.91 PEESA also targets those who provide
underwriting services or insurance or who provide certain upgrades or installation services.
Sanctions do not apply to nonbusiness entities of the EU, member states, or certain other non-EU
governments.

88 For more, see CRS In Focus IF11138, Russia’s Nord Stream 2 Natural Gas Pipeline to Germany, by Paul Belkin,
Michael Ratner, and Cory Welt.
89 America Hernandez, “3 Hurdles Still Facing the Nord Stream 2 Pipeline,” Politico, September 12, 2021.
90 Executive Order 14039 of August 20, 2021, “Blocking Property with Respect to Certain Russian Energy Export
Pipelines,” 86 Federal Register 47205.
91 On TurkStream, see CRS In Focus IF11177, TurkStream: Russia’s Southern Pipeline to Europe, by Sarah E. Garding
et al.
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PEESA provides for a 30-day wind-down period; exceptions for repairs, maintenance,
environmental remediation, and safety; and a national security waiver. In addition, PEESA
provides for the termination of sanctions if the President certifies to Congress “that appropriate
safeguards have been put in place”
 to minimize Russia’s ability to use the sanctioned pipeline project “as a tool of
coercion and political leverage”; and
 to ensure “that the project would not result in a decrease of more than 25 percent
in the volume of Russian energy exports transiting through existing pipelines in
other countries, particularly Ukraine, relative to the average monthly volume of
Russian energy exports transiting through such pipelines in 2018.”
In February 2021, the Biden Administration identified the previously designated Fortuna and its
owner as also subject to sanctions under PEESA. In May 2021, the Administration designated an
additional 13 vessels and four entities under PEESA; in August and November 2021, it
designated another three vessels and three entities.
In May 2021, the Administration waived the application of new sanctions on Nord Stream 2 AG,
its chief executive officer, and corporate officers (Nord Stream 2 AG is a Swiss-based company
Gazprom established to construct and operate the pipeline). Some Members of Congress have
urged the Administration to impose additional sanctions to prevent the Nord Stream 2 pipeline
from becoming operational.
In addition to these legislative provisions, E.O. 14024 provides for sanctions on Russian
individuals and entities responsible for, among other harmful activities, “cutting or disrupting gas
or energy supplies to Europe, the Caucasus, or Asia.”92
Other Sanctions Programs
The United States imposes economic sanctions on Russian individuals and entities in response to
various other objectionable activities. These activities include weapons proliferation, trade with
North Korea in violation of U.N. Security Council requirements, support for the Syrian and
Venezuelan governments, transnational crime, and international terrorism.
Weapons Proliferation
Several laws require the President to impose sanctions on those the President determines have
engaged in trade in weapons of mass destruction or advanced conventional weapons.93
Restrictions cover a range of activities and can include a one- to two-year cutoff of procurement
contracts with the U.S. government and restrictions on import and export licensing. Restrictions
also may include a denial of U.S. foreign aid, sales of defense articles and defense services
subject to U.S. export control for national security and foreign policy purposes (U.S. Munitions
List items), and export licenses for dual-use goods and services (Commerce Control List).94

92 Executive Order 14024 of April 15, 2021, “Blocking Property with Respect to Specified Harmful Foreign Activities
of the Government of the Russian Federation,” 86 Federal Register 20249.
93 See CRS Report RL31502, Nuclear, Biological, Chemical, and Missile Proliferation Sanctions: Selected Current
Law
, by Dianne E. Rennack.
94 Defense articles and defense services subject to U.S. export controls for national security and foreign policy purposes
are identified on the U.S. Munitions List, as established in Section 38 of the Arms Export Control Act (22 U.S.C.
2778). Dual-use goods and services similarly subject to export controls are identified on the Commerce Control List, 15
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Pursuant to the Iran, North Korea, and Syria Nonproliferation Act, as amended (INKSNA; (P.L.
106-178; 50 U.S.C. 1701 note), Russian state-owned arms exporter Rosoboronexport and at least
nine other Russian entities currently are denied most U.S. government procurement contracts,
export licenses, and trade in U.S. Munitions List-controlled goods and services. Weapons
proliferation sanctions against Rosoboronexport are in addition to Ukraine-related sectoral
sanctions imposed on the agency in December 2015 and its designation in April 2018 as an SDN
for providing support to the Syrian government.95 Restrictions against entering into government
contracts and other transactions with Rosoboronexport have been stated in annual Defense
appropriations acts since 2013 (see “Restrictions on U.S. Government Funding,” below).96
BIS periodically has imposed
Weapons Proliferation Sanctions on Russia:
restrictions for suspected violations
Historical Background
of the EAR with respect to exports
The United States has imposed various proliferation-related
to Russia for military and other
sanctions on Russian entities over the last 25 years related to
purposes.97
weapons sales and assistance to Iran, Syria, and North Korea. In
1998-1999, 10 Russian entities became subject to proliferation
In December 2017, BIS imposed
sanctions for providing supplies and assistance to Iran’s missile and
export-licensing restrictions on two
nuclear programs. In 1999-2004, another six entities became
entities for producing a ground-
subject to sanctions for providing lethal military equipment to Iran
or other state sponsors of terrorism. Sanctions on these entities
launched cruise missile system and
expired or were removed by the Clinton, Bush, and Obama
associated launcher in violation of
Administrations.
the Intermediate-Range Nuclear
State-owned arms exporter Rosoboronexport first became subject
Forces Treaty (INF Treaty). Due to
to U.S. sanctions in 2006 pursuant to the Iran Nonproliferation Act
Russia’s failure to return to
of 2000 (P.L. 106-178). The United States again imposed sanctions
compliance with the INF Treaty, the
on Rosoboronexport, along with other Russian defense entities,
pursuant to P.L. 106-178, as amended (also 2006) and the Iran,
North Korea, and Syria Nonproliferation Act, as amended ( 2008;
P.L. 106-178; 50 U.S.C. 1701 note). The Obama Administration did
not renew proliferation sanctions on Rosoboronexport in 2010; it
reapplied them in 2015.

CFR Part 774 Supplement 1, pursuant to authorities in the Export Control Act of 2018 (P.L. 115-232, Title XVII, Part
I) to the extent it continues regulations issued under the Export Administration Act of 1979 (P.L. 96-72; 50 U.S.C.
4601 et seq.) (see, in particular, §1758(g)(2) of the 2018 act). The Commerce Control List, under the Export Control
Act of 2018 (§1759), is subject to review not later than 270 days after the date of enactment. The act was signed into
law on August 13, 2018.
95 Two other Russian defense firms, the Instrument Design Bureau (precision-guided weapons) and NPO
Mashinostroyenia (rockets and missiles), also have been subject to recurring U.S. proliferation sanctions since 2014, in
addition to being designated pursuant to Ukraine-related executive orders.
96 The prohibitions against transactions with Rosoboronexport did not apply to contracts related to the maintenance or
repair of Mi-17 helicopters purchased by the United States “for the purpose of providing assistance to the security
forces of Afghanistan, as well as for the purpose of combating terrorism and violent extremism globally.” They also did
not apply to procurement related to the purchase or maintenance of optical sensors that “improve the U.S. ability to
monitor and verify Russia’s Open Skies Treaty compliance.” U.S. Department of State, “Imposition of
Nonproliferation Measures Against Rosoboronexport, Including a Ban on U.S. Government Procurement,” 83 Federal
Register
21333, May 9, 2018.
97 In 2012, for example, the U.S. Department of Justice made public an indictment of eleven U.S. and Russian
companies and individuals for the illegal export of “high-tech microelectronics from the United States to Russian
military and intelligence agencies.” Concurrently, the Department of Commerce’s BIS imposed restrictions on about
165 individuals and entities (Russians and others) for suspected involvement in procurement and delivery of items to
Russia for military-related and other governmental or related end uses in violation of export and arms trade regulations.
U.S. Department of Justice, “Russian Agent and 10 Other Members of Procurement Network for Russian Military and
Intelligence, Operating in the U.S. and Russia, Indicted,” press release, October 9, 2012; and BIS, “Addition of Certain
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United States withdrew from the treaty in August 2019.98
North Korea Sanctions Violations
The U.N. Security Council, beginning in 2006, has required its member states to curtail a range of
diplomatic, finance, trade, and exchange relations with North Korea. The Security Council took
action in response to North Korea’s withdrawal from the Treaty on Non-Proliferation of Nuclear
Weapons, testing of nuclear weapons, and efforts to develop missile delivery systems. Security
Council resolutions also have drawn attention to North Korea’s abuse of diplomatic privileges
and immunities, money laundering, bulk cash smuggling, disruption of regional stability, and
disregard for the human rights conditions of its civilian population.99
To meet the United States’ U.N. obligations, and to implement requirements enacted in the North
Korea Sanctions and Policy Enhancement Act of 2016 (P.L. 114-122; 22 U.S.C. 9201 et seq.), as
amended by the Korean Interdiction and Modernization of Sanctions Act (CAATSA, Title III), the
President has issued a series of executive orders to block assets, transactions, and travel of
designated North Korean individuals and entities. These sanctions also apply to other foreign
individuals and entities that engage in trade or support North Korean designees.100
Treasury currently designates more than 20 Russia-related individuals, entities, and vessels for
evading sanctions restricting trade and financial transactions with North Korea. Designations
include the following:
 A Russian oil company and its subsidiary (both delisted in 2020 after they were
deemed to be in compliance), three Russian individuals, and two Singapore-
based companies those individuals control for trade in petroleum with North
Korea, under E.O. 13722 of March 15, 2016 (designated in June and August
2017)
 Two Russian entities and two related individuals for providing supplies and
procuring metals to a North Korean company designated in 2009 for its weapons
of mass destruction programs, under E.O. 13382 of June 28, 2005 (June 2017)
 A Russian bank for “facilitating a significant transaction on behalf of an
individual designated for weapons of mass destruction-related activities,” under
E.O. 13810 of September 20, 2017 (August 2018)101

Persons to the Entity List,” 77 Federal Register 61249, October 9, 2012.
98 BIS, “Addition of Certain Persons to the Entity List,” 82 Federal Register 60304, December 20, 2017. For more, see
CRS In Focus IF11051, U.S. Withdrawal from the INF Treaty: What’s Next?, by Amy F. Woolf.
99 See CRS Report R41438, North Korea: Legislative Basis for U.S. Economic Sanctions, by Dianne E. Rennack.
100 The E.O.s referenced in this section are E.O. 13382 of June 28, 2005, “Blocking Property of Weapons of Mass
Destruction Proliferators and Their Supporters,” 70 Federal Register 38567; E.O. 13722 of March 15, 2016, “Blocking
Property of the Government of North Korea and the Workers’ Party of Korea, and Prohibiting Certain Transactions
With Respect to North Korea,” 81 Federal Register 14943; and E.O. 13810 of September 20, 2017, “Imposing
Additional Sanctions With Respect to North Korea,” 82 Federal Register 44705. Other North Korea-related E.O.s are
E.O. 13466 (June 26, 2008), E.O. 13551 (August 30, 2010), E.O. 13570 (April 18, 2011), and E.O. 13687 (January 2,
2015).
101 According to the Treasury Department, the bank had a commercial relationship with North Korean entities since at
least 2009. U.S. Department of the Treasury, “Treasury Targets Russian Bank and Other Facilitators of North Korean
United Nations Security Council Violations,” press release, August 3, 2018.
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 Two Russian shipping companies and six vessels for involvement “in the ship-to-
ship transfer of refined petroleum products with North Korea-flagged vessels,”
under E.O. 13810 (August 2018)102
 A Russia-based front company for a China-based information technology
company that “is managed and controlled by North Koreans” and facilitates the
exportation of information technology workers from North Korea, under E.O.
13722 and E.O. 13810 (September 2018)103
 A Russian institution for helping North Korea evade sanctions through the
provision of financial services to a subsidiary of North Korea’s primary foreign
exchange bank and a zinc export company, under E.O. 13382 (June 2019)
 A Russian construction company for seeking and receiving work permits for
workers from North Korea, under E.O. 13722 (November 2020)
 A Russian entity and a related individual for weapons proliferation-related
transactions, under E.O. 13382 (January 2022)
Syria-Related Sanctions
In a series of executive orders dating back to 2004, the President has sought to block trade and
transactions with the government of Syria and its supporters. The U.S. government has imposed
sanctions in response to Syria’s past occupation of Lebanon, support of international terrorism,
pursuit of weapons of mass destruction and the means to deliver them, undermining of
international efforts to stabilize Iraq, and escalating violence against its own people.104
In April 2018, OFAC designated Russia’s state-owned arms exporter Rosoboronexport and an
associated bank pursuant to E.O. 13582 (August 2011) for providing material support and
services to the government of Syria.105 Previously, during the Obama Administration, OFAC
designated two other banks, which have since had their licenses revoked, and 12 related
individuals pursuant to E.O. 13582.
In November 2018, OFAC designated under E.O. 13582 one Russian individual and three Russia-
based entities for providing material support and services to the government of Syria. Treasury
said these designees were part of “a complex scheme Iran and Russia have used to bolster the
Assad regime and generate funds for Iranian malign activity.” This scheme involved moving oil
from Iran to Syria and funneling funds to the Islamic Revolutionary Guard Corps-Qods Force, its
proxies, and Hamas and Hezbollah.106

102 U.S. Department of the Treasury, “Treasury Targets Russian Shipping Companies for Violations of North Korea-
Related United Nations Security Council Resolutions,” press release, August 21, 2018.
103 U.S. Department of the Treasury, “Treasury Targets North Korea-Controlled Information Technology Companies in
China and Russia,” press release, September 13, 2018.
104 The E.O. referenced in this section is E.O. 13582 of August 17, 2011, “Blocking Property of the Government of
Syria and Prohibiting Certain Transactions with Respect to Syria,” 76 Federal Register 52209. The initial declaration
of a national emergency relating to Syria is stated in E.O. 13338 of May 11, 2004, “Blocking Property of Certain
Persons and Prohibiting the Export of Certain Goods to Syria,” 69 Federal Register 26751.
105 Before Rosoboronexport was designated as an SDN in April 2018, SSI sectoral sanctions applied to it as a
subsidiary of the Russian defense conglomerate Rostec. Other sanctions relating to weapons proliferation also applied
(see “Weapons Proliferation”).
106 The Islamic Revolutionary Guard Corps-Qods Force, Hamas, and Hezbollah are each subject to U.S. sanctions as
foreign terrorist organizations (FTO), specially designated global terrorists (SDGT), and for their activities in the
Middle East. One of the designated entities also was designated for Iran-related activities and as an SDGT. Another
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In September 2019, OFAC designated one entity under E.O. 13582 and associated individuals and
vessels under the Ukraine-related E.O. 13685 for providing material support and services to the
government of Syria and for evading Ukraine-related sanctions. Treasury said the entity was
serving as a front company for a sanctioned entity as part of a “scheme to facilitate the [illicit
transfer] of jet fuel to Russian forces operating in Syria.”107
Venezuela-Related Sanctions
In March 2019, OFAC designated a bank that is jointly owned by Russian and Venezuelan state-
owned companies under E.O. 13850 for providing support to Venezuela’s state-owned oil
company, Petróleos de Venezuela, S.A. (PdVSA).108 The Administration designated PdVSA in
January 2019 to curb the availability of resources to the regime of Nicolás Maduro.
In February and March 2020, OFAC designated two subsidiaries of Russian state-owned oil
company Rosneft and one corporate officer for operating in Venezuela’s oil sector under E.O.
13850.
In January 2021, Treasury designated under E.O. 13850 two Russian-flagged vessels and their
registered owners, among others, for attempting to evade U.S. sanctions.
Transnational Crime
Russian nationals are subject to sanctions for activities related to transnational crime.109 OFAC
currently designates at least 15 Russian individuals and six entities for their roles in transnational
criminal organizations (TCOs). In December 2017, OFAC designated as a TCO the “Thieves-in-
Law,” which it characterized as “a Eurasian crime syndicate that has been linked to a long list of
illicit activity across the globe.”110 OFAC designated 10 individuals (Russian nationals and
others) and two entities as TCOs for their relation to the Thieves-in-Law; these designees include
several individuals OFAC previously designated, during the Obama Administration, as part of a
related TCO, the Brothers’ Circle.111 When OFAC designated the Thieves-in-Law, it delisted the
Brothers’ Circle and some related individuals and entities.

was designated previously for Iran-related activities and as an SDGT. U.S. Department of the Treasury, “Treasury
Designates Illicit Russia-Iran Oil Network Supporting the Assad Regime, Hizballah, and HAMAS,” press release,
November 20, 2018.
107 U.S. Department of the Treasury, “Treasury Targets Sanctions Evasion Scheme Facilitating Jet Fuel Shipments to
Russian Military Forces in Syria,” press release, September 26, 2019.
108 E.O. 13850 of November 1, 2018, “Blocking Property of Additional Persons Contributing to the Situation in
Venezuela,” 83 Federal Register 55243. The initial declaration of a national emergency relating to Venezuela is stated
in E.O. 13692 of March 8, 2015, “Blocking Property and Suspending Entry of Certain Persons Contributing to the
Situation in Venezuela,” 80 Federal Register 12747.
109 E.O. 13581 of July 24, 2011, “Blocking Property of Transnational Criminal Organizations,” 76 Federal Register
44757. Although the E.O. does not explicitly address denial of entry into the United States of transnational crime
(TCO) designees, the Secretary of Homeland Security, Secretary of State, and Attorney General could draw on
authorities stated in the Immigration and Nationality Act (at 8 U.S.C. 1189) to deny entry.
110 U.S. Department of the Treasury, “Treasury Targets the ‘Thieves-in-Law’ Eurasian Transnational Criminal
Organization,” press release, December 22, 2017.
111 The Obama Administration designated the Brothers’ Circle as one of four transnational criminal organizations under
E.O. 13581 of July 24, 2011 (the other three were the Italian Camorra, Japanese Yakuza, and Mexico-based Loz Zetas).
The Administration described the Brothers’ Circle as “a criminal group composed of leaders and senior members of
several Eurasian criminal groups that ... serves as a coordinating body for several criminal networks, mediates disputes
between the individual criminal networks, and directs member criminal activity globally.” It indicated that many
Brothers’ Circle members “share a common ideology based on the ‘thief-in-law’ tradition.” In all, the Obama
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Terrorism
Russian nationals are subject to sanctions related to international terrorism.112 OFAC has
designated at least two entities and 12 affiliated individuals, in Russia or as fighters abroad, as
Specially Designated Global Terrorists (SDGTs). The Caucasus Emirate, a terrorist and insurgent
group in Russia’s North Caucasus region, was established in 2007; OFAC listed its founder, Doku
Umarov, as an SDGT in 2010 (he was killed in 2013).113 OFAC designated the Caucasus Emirate
itself in May 2011. In 2015, the Islamic State recognized as its local affiliate the Caucasus
Province (Vilayet), which reportedly was established by insurgents previously affiliated with the
Caucasus Emirate. OFAC designated the Caucasus Province as an SDGT in September 2015.
Restrictions on U.S. Government Funding
As in past years, FY2021 appropriations restrict assistance to the Russian government. The
Department of Defense Appropriations Act, 2021 (P.L. 116-260, Division C), prohibits the use of
defense funding to make a loan or loan guarantee to Rosoboronexport or any of its subsidiaries
(§8102).114 The Department of State, Foreign Operations, and Related Programs Appropriations
Act, 2021 (P.L. 116-260, Division K), requires country notification procedures to be invoked for
foreign aid to Russia (§7015(f)). This act also prohibits funds from being made available to
Russia’s central government (§7047(a)), a restriction in place since FY2015.
Pursuant to the Trafficking Victims Protection Act, the State Department every year since 2013
has identified Russia as a Tier 3 nation that fails to meet minimum standards for the elimination
of human trafficking and is not making significant efforts to do so. As a result, the President does
not provide non-humanitarian, non-trade-related assistance to the Russian government and denies
U.S. support for multilateral development loans or other funds to the Russian government. For
FY2022, however, the President determined it is in the U.S. national interest to waive restrictions
on funds for Russia’s participation in educational and cultural exchange programs as described in
Section 110(d)(1)(A)(ii) of the act.115

Administration designated a related 23 individuals (Russian nationals and others) and 7 entities pursuant to E.O. 13581.
U.S. Department of the Treasury, “Fact Sheet: New Executive Order Targets Significant Transnational Criminal
Organizations,” July 25, 2011; and U.S. Department of the Treasury, “Treasury Designates Key Members of the
Brothers’ Circle Criminal Organization,” press release, December 20, 2012.
112 E.O. 13224 of September 23, 2001, “Blocking Property and Prohibiting Transactions With Persons Who Commit,
Threaten To Commit, or Support Terrorism,” 66 Federal Register 49079; E.O. 13268 of July 2, 2002, “Termination of
Emergency With Respect to the Taliban and Amendment of Executive Order 13224 of September 23, 2001,” 67
Federal Register 44751; and E.O. 13372 of February 16, 2005, “Clarification of Certain Executive Orders Blocking
Property and Prohibiting Certain Transactions,” 70 Federal Register 8499.
113 OFAC also designated Umarov’s successor as a Specially Designated Global Terrorist less than a month before his
death in 2015. After a designee dies, an SDN remains designated so that his or her estate remains subject to blocking.
Descendants may appeal to OFAC to have assets released.
114 The restriction in Defense appropriations has been in place since FY2013.
115 The waiver justification notes the value of including “Russian teachers, academics, doctors, nurses, researchers, and
legal professionals, ... individuals employed at public institutions, reform-oriented government officials at the regional
or municipal level, and teachers of minority languages and cultures” in educational and cultural exchanges. Presidential
Determination No. 2022-06, “Presidential Determination with Respect to the Efforts of Foreign Governments
Regarding Trafficking in Persons,” White House publication, December 21, 2021. For additional information on the
trafficking in persons report and associated aid restrictions, see CRS Report R44953, The State Department’s
Trafficking in Persons Report: Scope, Aid Restrictions, and Methodology
, by Michael A. Weber, Katarina C. O'Regan,
and Liana W. Rosen.
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Under the International Religious Freedom Act of 1998, as amended (P.L. 105-292, 22 U.S.C.
6401 et seq.), since 2018 Russia has been included on the Special Watch List identifying
“governments that have engaged in or tolerated severe violations of religious freedom.”116 The
Special Watch List was established in 2016 to publicly name countries that have severe religious
freedom violations but whose treatment of religious freedoms was judged by the President to not
meet the criteria for designation as a Country of Particular Concern (CPC). A Special Watch List
designation may serve as a warning that the United States could designate the foreign nation as a
CPC in a subsequent year. If Russia were to be designated a CPC, it would become subject to
potential diplomatic and economic sanctions that could range from private demarches to
prohibitions on export licensing, procurement contracts, and transactions through U.S. financial
institutions.117
Russian Countersanctions
The Russian government has responded to U.S. and other sanctions by imposing a variety of
retaliatory measures, also known as countersanctions. The day the Senate passed the Sergei
Magnitsky Act in December 2012, the Russian government announced new restrictions on
imported beef, pork, and poultry that, within a few months, led to a major decline in U.S. meat
imports to Russia.118 Several days after President Obama signed the Sergei Magnitsky Act into
law, the Russian parliament voted to ban U.S. adoptions of Russian children.119 It also introduced
a visa ban against U.S. citizens whom Russia characterized as being involved in human rights
violations or crimes against and persecution of Russian citizens. The day after OFAC issued its
first designations under the Sergei Magnitsky Act in April 2013, the Russian government issued a
list of U.S. citizens prohibited from entering Russia.120
Russia also imposed countersanctions in response to U.S. and EU sanctions related to Russia’s
invasion of Ukraine. These measures included additional travel prohibitions and a ban on the
import of agricultural products from countries that had imposed sanctions on Russia.
After the United States’ imposition of new designations of Russian government officials and
politically connected billionaires and their holdings in April 2018, President Putin signed into law
an act authorizing, but not requiring, restrictions related to trade with the United States and other
unfriendly states, as well as foreign access to Russian public procurement and privatization.121

116 U.S. Department of State, “Briefing on Religious Freedom Designations,” December 11, 2018.
117 Actions against Countries of Particular Concern are subject to potential exceptions and waivers. For additional
information, see CRS In Focus IF10803, Global Human Rights: International Religious Freedom Policy, by Michael
A. Weber.
118 Ellen Barry, “Russia Announces Barriers on Imports of U.S. Meat,” New York Times, December 8, 2012; and Dina
Gusovsky, “Russia’s U.S. Meat Ban: What’s the Beef?” CNBC, February 20, 2013.
119 Charles Clover, “Russia Bans Adoptions by U.S. Citizens,” Financial Times, December 21, 2012. This Russian ban
on U.S. adoptions, taken in response to the Sergei Magnitsky Act, emerged as an issue in the U.S. Special Prosecutor’s
investigation of possible Russian interference in the 2016 U.S. presidential election. See, for example, Jo Becker, Matt
Apuzzo, and Adam Goldman, “Trump Team Met with Lawyer Linked to Kremlin During Campaign,” New York Times,
July 8, 2017.
120 U.S. Department of State, “Release of Magnitsky List,” April 12, 2013; and VOA News, “Russia Bans 18 Citizens,”
April 13, 2013.
121 Konstantin Kroll, Mikhail Usubyan, and Harry Clark, “Further Update—Russian Counter-Sanctions Measures and
New U.S. Sanctions Against Russia,” Orrick, June 18, 2018; and Reuters, “Factbox: Russia’s List of U.S. Imports That
Could Be Banned,” April 13, 2018.
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In response to Biden Administration sanctions and diplomatic expulsions in April 2021, Russian
authorities took reciprocal actions and said Russia would “limit and suspend the activities” of
U.S. nongovernmental organizations and foundations that “directly interfere in [Russian] political
life.” (Russian nationals already are prohibited from working with or receiving money from
several U.S. nongovernmental organizations, and other organizations have been required to
publicly label themselves as “foreign agents” or cease operations.) Russian officials said they
would hold in reserve “painful” measures against U.S. businesses.122
Since 2017, the Russian government has responded to the United States’ expulsion of Russian
officials from diplomatic missions in the United States and orders to close some diplomatic
offices with a series of tit-for-tat diplomatic reductions and closures.123 In 2021, Russian
authorities prohibited the employment of Russian nationals in the U.S. diplomatic mission. As a
result, U.S. embassy and consular operations in Russia were reduced substantially.124
U.S. and EU Coordination on Sanctions
Like the United States, the EU has imposed sanctions—or restrictive measures in EU parlance—
in response to Russia’s 2014 invasion of Ukraine. The EU also has imposed sanctions in response
to Russia’s use of chemical weapons, human rights violations, and malicious cyber activity.
Authorized sanctions include travel bans and asset freezes. The EU has imposed these sanctions
largely in cooperation with the United States. EU sanctions are similar, but not identical, to U.S.
sanctions.
Imposing EU sanctions requires the unanimous agreement of all EU member states. Most EU
sanctions are imposed for a defined period of time (usually six months or a year) to incentivize
change and provide the EU with flexibility to adjust the sanctions as warranted. Unanimity
among EU member states also is required to renew (i.e., extend) EU sanctions.
Comparing U.S. and EU Ukraine-Related Sanctions
Since Russia’s invasion of Ukraine in 2014, the United States and the EU have pursued largely
similar policies—including related to sanctions—aimed at restoring Ukraine’s territorial integrity
and supporting Ukraine’s governance reforms. Observers have viewed U.S.-EU cooperation in
imposing sanctions on Russia and coordination on other political and diplomatic responses to
Russia’s invasion as a high point in transatlantic relations and as a means to prevent Russia from
driving a wedge between the United States and Europe.
The EU has tied lifting sanctions on Russia to the full implementation of the Minsk agreements
that provide a framework for conflict resolution in eastern Ukraine and asserts that it is
committed to maintaining sanctions until this goal is achieved. At the same time, questions persist
in some EU countries about the sanctions’ effectiveness, especially amid concerns that sanctions
could be hindering EU relations with Russia on other global priorities and harming certain
European business interests, although the overall impact on EU trade appears to be limited. Some

122 Robyn Dixon, “Russia to Expel 10 U.S. Diplomats in Response to Biden Administration Sanctions,” Washington
Post
, April 16, 2021; and Henry Foy, “Russia Counters U.S. Sanctions with Diplomat Expulsions,” Financial Times,
April 16, 2021.
123 For more, see CRS Report R46761, Russia: Foreign Policy and U.S. Relations, by Andrew S. Bowen and Cory
Welt.
124 Robbie Gramer, “Under Putin’s Rules, U.S. Mission in Russia Left with Skeleton Crew,” Foreign Policy, July 29,
2021; and Joel Gehrke, “State Department Struggles to Keep Moscow Embassy Open Due to Staffing Feud with
Russia,” Washington Examiner, October 27, 2021.
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European officials have periodically floated ideas about restructuring the sanctions. Others firmly
reject suggestions to relax or recalibrate EU sanctions.
EU sanctions in response to Russia’s invasion of Ukraine consist of three measures:
Restrictive measures on individuals and entities in Russia and Ukraine
believed to be involved in the annexation of Crimea and destabilization of
eastern Ukraine.
Designees are subject to asset freezes and, for individuals, visa
bans. As of January 2022, the EU has designated 185 individuals and 48 entities
(Council Decision 2014/145/CFSP, March 17, 2014).
Economic sanctions targeting Russia’s finance, defense, and energy sectors
(sectoral sanctions). The EU requires its member states to impose lending and
investment restrictions on five major state-controlled Russian banks, three
defense firms, and three energy companies, as well as their subsidiaries outside
the EU. The sanctions also ban the import and export of arms; the sale of dual-
use goods and technology to Russian military end users and nine mixed
companies; and sales of equipment, technology, and services for oil-development
projects related to deepwater, Arctic offshore, and shale exploration (Council
Decision 2014/512/CFSP, July 31, 2014).
Restrictions on economic relations with Ukraine’s occupied Crimea region.
The EU has banned EU individuals and EU-based companies from importing
goods, exporting certain goods and technologies, and providing tourism services
to Ukraine’s Crimea region. The EU also has restricted trade and investment in
certain economic sectors and infrastructure projects (Council Decision
2014/386/CFSP, June 23, 2014).
In addition, in 2014, the EU imposed restrictive measures on individuals identified as responsible
for the misappropriation of Ukrainian state funds or for the abuse of office causing a loss of
Ukrainian public funds. The EU hoped to prevent the transfer of such funds outside of Ukraine
and to facilitate their recovery. As of January 2022, the EU has frozen assets of and imposed visa
bans on 8 former Ukrainian officials (originally 22), including ex-Ukrainian president Viktor
Yanukovych (Council Decision 2014/119/CFSP, March 5, 2014).
International Sanctions Related to Russia’s Invasion of Ukraine
U.S. and EU sanctions in response to Russia’s invasion of Ukraine have been complemented by similar blocking and
sectoral sanctions imposed by other countries, including Australia, Canada, Japan, and Iceland. Three
countries—Norway and EU candidate countries Albania and Montenegro—formally align their sanctions on
Russia with those imposed by the EU. Switzerland also has imposed sanctions, including regulations to prevent
EU-designated individuals and entities from using the Swiss financial system to bypass sanctions. Ukraine has an
extensive sanctions regime against Russia, which has responded with its own wide-ranging sanctions on Ukrainian
individuals and entities.
Despite U.S. and EU coordination on sanctions, their lists of designated individuals and entities
are not identical. Various legal and political reasons account for some of the differences in U.S.
and EU designations. The EU has imposed sanctions on more individuals and entities directly
related to the fighting in Ukraine—military officials, insurgents, and battalions—than has the
United States. The United States has specifically designated more companies operating in Crimea
and entities affiliated with other designated individuals and entities, whereas the EU provides for
blanket restrictions on Crimea-related activities and against affiliated individuals and entities. The
EU is unable to impose restrictive measures on some individuals who hold dual citizenship with
EU countries.
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Since 2014, several individuals have been removed from the EU sanctions list. Unlike the United
States, which requires a decedent’s survivors to petition for removal, the EU removes individuals
from its sanctions list due to death. In addition, several designees have successfully petitioned for
their removal.
EU and U.S. restrictions against lending and/or investments with entities in specific sectors
mostly overlap and target a handful of key companies and their subsidiaries in the financial,
defense, and energy sectors, including exports and services related to deepwater, Arctic offshore,
or shale oil projects in Russia (see Table D-1).
The manners in which the United States and the EU employ this measure differ somewhat and
have changed over time. The United States has explicitly identified several companies, including
Gazprom, with which sales of equipment, technology, and services for certain oil projects are
prohibited; by contrast, the EU has not named specific companies to which these prohibitions
apply. In addition, the EU does not impose sanctions on such oil projects worldwide, as does the
United States.
EU and U.S. policies are comparable in restricting most arms trade with and dual-use exports to
Russia, but the EU applied arms-trade sanctions to future contracts only. Reports suggest,
however, that the arms-trade sanctions—and ongoing concern about Russia’s actions in Ukraine
and Russia’s military resurgence—prompted EU members to reevaluate some existing weapons
system sales and licenses. France, for example, canceled a contract with Russia for two Mistral
helicopter carriers. Germany also canceled a contract to supply Russia with a $155 million
combat simulation center. Central and Eastern European countries have been advancing plans to
phase out Russian-origin military equipment and replace it with more modern U.S. and European
equipment.125
The EU and the United States also addressed the issue of existing sales and service contracts on
energy development projects differently. The EU allowed for the continuation of existing
contracts and agreements, in certain cases with authorization at the national level. The United
States generally prohibited, other than a brief wind-down period, the continuation of existing
contracts and agreements, unless otherwise authorized by OFAC. This difference led, for instance,
to Eni (an Italian energy company) continuing its deepwater exploration in the Black Sea in
partnership with Russian state-controlled oil company Rosneft; by contrast, ExxonMobil
withdrew from certain joint ventures with Rosneft in 2018 after failing in 2017 to secure a waiver
from the Treasury Department to move forward with its own oil exploration project in the Black
Sea.126
Neither the United States nor the EU has employed sectoral sanctions that broadly target Russia’s
gas sector or state-controlled gas company Gazprom. Reports suggest that as the United States
and EU worked to develop sanctions on Russia in 2014, they agreed to avoid measures that could
harm the other’s interests, including in relation to the production and supply of Russian gas.127 As
discussed above, many EU countries dependent on Russian gas supplies were particularly worried

125 Jeevan Vasagar, “Russia Sanctions Take Toll on Germany,” Financial Times, August 25, 2014; Sabrina Tavernise,
“Canceling Deal for 2 Warships, France Agrees to Repay Russia,” New York Times, August 5, 2015; and Aaron Mehta,
“Inside America’s Multimillion-Dollar Plan to Get Allies Off Russian Equipment,” Defense News, May 29, 2019.
126 Jack Farchy and Chiara Albanese, “Sanctions-Proof Oil Rig Thwarts U.S. Policy from Cuba to Russia,” Bloomberg,
December 19, 2017; and Henry Foy and Ed Crooks, “ExxonMobil Abandons Joint Ventures with Russia’s Rosneft,”
Financial Times, March 1, 2018.
127 Deutsche Welle, “U.S. Sanctions Experts: European Concerns Are Exaggerated,” July 28, 2017; and Boris Toucas,
“Russia Sanctions Act Is Enacted: Is President Trump Europe’s Best Ally in Managing the Impact on the Transatlantic
Link?” Center for Strategic and International Studies, August 4, 2017.
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about sanctions that could impede the flow of Russian gas and harm relations with Russia in this
area. The United States and the EU apply financial restrictions to two Gazprom subsidiaries
(Gazpromneft, its oil production and refining subsidiary, and Gazprombank, a financial
institution). U.S. restrictions on deepwater, Arctic offshore, and shale oil projects also specifically
apply to Gazprom. In addition, the United States applies lending restrictions to Novatek, a private
Russian gas company. Neither the United States nor the EU has applied sanctions targeting gas
production or gas and oil trade.
EU Concerns About U.S. Sanctions After 2017
Given close U.S.-EU coordination on sanctions related to Russia’s invasion of Ukraine, some in
the EU became concerned from 2017 about what they viewed as a more unilateral U.S. approach
to sanctions. Many in the EU were dismayed, for example, by certain provisions in CRIEEA as
the legislation evolved. European leaders and EU officials recognized the main intent of CRIEEA
was to codify and strengthen sanctions on Russia, including many with parallels in EU
legislation. At the same time, European policymakers were uneasy with some of CRIEEA’s initial
provisions, which they viewed as having been drafted without regard for the EU’s role as a U.S.
partner.
EU concerns were accommodated to some degree by language inserted in CRIEEA specifying
that the President should “continue to uphold and seek unity” with European partners on
sanctions (§212) and that new U.S. sanctions on pipeline ventures would not be imposed without
coordinating with U.S. allies (§232). Following CRIEEA’s enactment, the European Commission
(the EU’s executive) expressed overall satisfaction that “European interests can thus be taken into
account in the implementation of any [U.S.] sanctions.”128
Nonetheless, some European officials and experts were skeptical of the Trump Administration’s
commitment to consult the EU and its member states ahead of imposing new sanctions, especially
amid broader European concerns about whether the Administration regards the EU as a partner or
a competitor. Those of this view pointed, for example, to the Trump Administration’s April 2018
designation of several Russian billionaires and the companies they control. Some media reports
suggested the Trump Administration issued these designations without significant prior
consultations with the EU or leading European governments.129
In particular, the designation of Rusal, a leading global producer of aluminum and the raw
material alumina, had potentially significant implications for Europe’s aluminum and
manufacturing sectors. Concern that the Administration would enforce CRIEEA’s secondary
sanctions against European firms that have commercial and financial dealings with Rusal (whose
facility in Ireland supplies many European aluminum producers) effectively halted such
transactions. The U.S. announcement also led to a rise in the price of alumina. European officials
warned that sanctions on Rusal could lead to plant closures, job losses, and the supply and
production chains of key European industries, ranging from the makers of aluminum cans and foil
to automobile and aerospace companies.130

128 European Commission, “European Commission President Juncker: New U.S. Sanctions on Russia Only After
Consultation of Allies,” August 2, 2017.
129 Ian Talley and Amrith Ramkumar, “U.S Extends Deadline for Investors to Disentangle from Rusal,” Wall Street
Journal
, April 23, 2018.
130 Neil Hume, Guy Chazan, and Harriet Agnew, “Europe in Diplomatic Push to Ease Russia Sanctions,” Financial
Times
, April 20, 2018.
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The Trump Administration appeared responsive to subsequent European entreaties (and those of
other international partners, such as Brazil) regarding the difficulties posed for them by Rusal’s
designation. Then-Treasury Secretary Mnuchin indicated that the “impact on our partners and
allies” contributed to a U.S. decision to extend the wind-down period for transactions with
Rusal.131 In January 2019, the Treasury Department removed sanctions on Rusal and two related
companies (see “Section 241 “Oligarch” List and Related Sanctions,” above).
In 2019, U.S.-EU tensions again arose over the enactment of PEESA, which established new
sanctions related to the construction of the Nord Stream 2 pipeline (see “Nord Stream 2: Energy
Exports as a Coercive or Political Tool,
” above). Despite reservations about Nord Stream 2 within
the European Commission and among some EU member states, EU officials asserted strong
opposition to PEESA, noting that the EU rejects as a “matter of principle” the imposition of
sanctions against EU companies conducting legitimate business in line with EU and European
law.132 The Trump Administration did not impose sanctions under PEESA (although on President
Trump’s last full day in office, the Trump Administration imposed Nord Stream 2-related
sanctions under Section 232 of CRIEEA).
The Biden Administration has sought to assuage these concerns and prioritize coordination with
the EU in imposing further sanctions on Russia. None of the sanctions the Biden Administration
has imposed pursuant to PEESA target European-based individuals or entities. In addition, U.S.
officials explained a May 2021 decision to waive the application of new sanctions on the Swiss-
based (but Russian-owned) Nord Stream 2 AG company and its corporate officers (some of
whom are EU citizens) as “in line with the President’s commitment to rebuild relations with our
allies and intended to create space for diplomacy with Germany to address the risks an
operational Nord Stream 2 pipeline would pose to European energy security and to Ukraine and
frontline NATO and EU countries.”133
Other EU Sanctions in Response to Russian Activities
U.S. officials also have highlighted coordination with the EU in imposing sanctions in response to
Russia’s alleged use of chemical weapons, cyberattacks, and human rights abuses. The March
2018 nerve agent attack in the UK reportedly perpetrated by Russian military intelligence agents
helped spur the EU to agree to a broad new sanctions regime in October 2018 targeting
individuals and entities involved in the development and use of chemical weapons.134 In January
2019, the EU imposed sanctions under this new regime on four GRU officers believed
responsible for or involved in carrying out the attack (including the head and deputy head of the
GRU). In October 2020, the EU imposed another round of chemical weapons sanctions on six
senior Russian officials and a Russian research institute in response to the chemical weapon
attack on Russian opposition figure Navalny.
In May 2019, the EU established a new framework enabling it to impose sanctions aimed at
deterring and responding to cyberattacks. These could be imposed on individuals or entities
directly responsible for cyberattacks or for providing support for such attacks. In July and

131 U.S. Department of the Treasury, “Treasury Extends Wind-Down Period for United Company RUSAL PLC,” press
release, April 23, 2018.
132 BBC News, “Nord Stream 2: Germany and Russia Decry U.S. Sanctions,” December 21, 2019; and RFE/RL,
“European Commission President Criticizes U.S. Nord Stream Sanctions,” December 27, 2019.
133 U.S. Department of State, “Briefing with Senior State Department Officials On European Energy Security,” July 21,
2021.
134 Council of the EU, “Chemical Weapons: The Council Adopts a New Sanctions Regime,” October 15, 2018.
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October 2020, the EU used this new regime to impose sanctions against six Russian individuals
and two entities for a 2015 cyberattack against the German federal parliament, the 2017
“NotPetya” global ransomware attack, and the 2018 attempted attack against the OPCW.135
In December 2020, the EU established a new human rights sanctions regime targeting individuals
“responsible for, involved in or associated with serious human rights violations and abuses
worldwide, no matter where they occurred.”136 For many years, some European leaders and EU
officials—including some members of the European Parliament—had called for an “EU
Magnitsky Act” that would target Russians (and others) complicit in human rights abuses. In
March 2021, the EU coordinated with the United States to impose sanctions against four Russian
officials, including Russia’s prosecutor general, under this new regime. The EU also has imposed
human rights sanctions on two officials from Russia’s Chechen Republic.
Economic Impact of Sanctions on Russia
Impact on Russia’s Economy Broadly
U.S. sanctions imposed on Russia in 2014 and in subsequent years appear to have had a negative
impact on Russia’s overall economy, although the size of the impact is modest compared with
other economic shocks. In particular, Russia’s economy arguably has been impacted more
significantly by changes in the global price for oil—Russia’s main export and source of
revenue—and the economic disruptions associated with the COVID-19 pandemic than by
sanctions.
In 2014, Russia faced, in addition to new
multilateral sanctions, a collapse in global
Figure 1. Economic Growth in Russia,
oil prices. Historically, fluctuations in
1994-2021
Russia’s economy have been closely
correlated with fluctuations in global oil
prices (Figure 1). Growth slowed to 0.7%
in 2014, and the economy contracted by
2.0% in 2015. The 2014-2015 recession
was, at the time, Russia’s longest in
almost 20 years.137 However, as oil prices
recovered, Russia’s economy stabilized
and grew at a modest pace between 2016
and 2019 (on average 1.5%), even as
some sanctions were tightened and
expanded.
The International Monetary Fund (IMF)

estimates that, between 2014 and 2018,
Source: IMF, World Economic Outlook Database,
the fall in oil prices had about three times
October 2021.
the effect of sanctions on Russia’s

135 Council of the EU, “EU Imposes the First Ever Sanctions Against Cyber-attacks,” July 30, 2020; and Council of the
EU, “Malicious Cyber-attacks: EU Sanctions Two Individuals and One Body over 2015 Bundestag Hack,” October
2020.
136 Council of the EU, “EU Adopts a Global Human Rights Sanctions Regime,” December 7, 2020.
137 Kathrin Hille, “Russia: Putin’s Balance Sheet,” Financial Times, April 7, 2016.
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economy. In particular, the IMF estimated in August 2019 that sanctions led growth to fall short
of expectations by about 0.2% per year since 2014. In comparison, according to IMF estimates,
the decline in global oil prices caused Russian growth to be about 0.6% lower than expectations
each year since 2014.138
Russia’s economy in 2020 was impacted largely by the disruptions in economic activity
associated with the COVID-19 pandemic and a sharp downturn in oil prices. The economy
contracted by about 3.0% in 2020. Russia’s economy rebounded sharply in 2021, by an estimated
4.7%, supported by higher oil prices and various factors mitigating the pandemic’s economic
impact (including Russia’s relatively small service sector and the government’s strong fiscal and
monetary policy response).139 Many economists view sanctions as a continued drag on economic
growth in Russia, along with a host of other structural problems in the economy (including
corruption and an ageing population).140
The modest macroeconomic effects of sanctions were largely by design of the Obama
Administration, the EU, and other international counterparts when they instituted sanctions in
response to Russia’s invasion of Ukraine in 2014. These sanctions do not broadly prohibit
economic activity with Russia. They were intended to be smart sanctions that target individuals
and entities responsible for offending policies and/or associated with key Russian policymakers
but inflicted minimal collateral damage to the Russian people and to the economic interests of
countries imposing sanctions.141
For example, more than half of the U.S. sanctions that block assets and restrict transactions target
individuals, not firms. Such sanctions may be consequential for the specific individuals involved
and may send important political messages, but they are unlikely to have broader effects on
Russia’s economy. Sanctions that block assets and restrict transactions on entities are mainly
limited to businesses controlled by designated individuals, companies that operate in Crimea, and
several defense and arms firms. Of Russia’s 20 largest firms, one (Rosoboronexport) is subject to
full blocking sanctions (Table E-1).142
More major Russian companies (9 of Russia’s 20 largest firms) are subject to sectoral sanctions,
which impose narrower restrictions on debt (and, in some cases, equity) and/or oil exploration
projects (Table E-1). Some sectoral sanctions were designed to make it harder for Russia to
modernize its oil sector with access to Western technology and capital. In 2016, a State
Department official explained that such sanctions were not designed to push Russia “over the
economic cliff” in the short run but to exert long-term pressure.143
Impact on Russian Firms
Even as the effects of sanctions on Russia’s economy as a whole have been relatively modest,
their impact on specific firms and sectors in some cases has been more significant. One study

138 IMF, Russian Federation: Staff Report for the 2019 Article IV Consultation, August 2019, p. 5.
139 IMF, Russian Federation: Staff Report for the 2020 Article IV Consultation, February 2021.
140 Ibid.
141 Ahn and Ludema, “The Sword and the Shield,” 2020 (footnote 1).
142 Congressional Research Service (CRS) analysis of data published by Russian media outlet RBC
(https://www.rbc.ru/rbc500/) on the largest firms in Russia and the U.S. Department of the Treasury’s Office of Foreign
Assets Control (OFAC) Specially Designated Nationals and Blocked Persons (SDN) List and Sectoral Sanctions
Identifications (SSI) List.
143 Robin Emmott, “Sanctions Impact on Russia to be Longer Term, U.S. Says,” Reuters, January 12, 2016.
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uses firm-level data to estimate the impact of U.S. and European sanctions in 2014 on Russian
firms.144 Based on data from between 2012 and 2016, the study finds that sanctioned firms on
average lost about one-quarter of their operating revenues, over one-half of their asset values, and
about one-third of their employees relative to their non-sanctioned peers. The authors argue that
the findings suggest sanctions effectively targeted firms with relatively minimal collateral damage
to other Russian firms.
Media reports also provide anecdotal examples of how sanctions have created economic frictions
at the firm level. For example, Rostec, a major state-owned defense conglomerate, saw profits
drop in 2014 from a loss in foreign investment caused by sanctions, Exxon canceled its
involvement in a joint venture with state-owned oil company Rosneft to comply with U.S.
sanctions requirements, and sanctions reportedly forced Rosneft to suspend an oil project in the
Black Sea.145 Media reports about the firm-level effects of sanctions appear to have become less
common in recent years, presumably as firms have adjusted to the sanctions.
Some Russian firms have weathered sanctions better than others. This discrepancy may be
attributable to a number of factors. First, the extent to which sanctions interrupted economic
transactions varies across sanction targets. It is not clear to what extent some sanctioned targets,
including Russian intelligence services, the Night Wolves (a motorcycle club), or the Eurasian
Youth Union, engage in significant economic transactions with the United States or in the U.S.
financial system.146 Such sanctions may be more symbolic than disruptive of economic activity.
Additionally, the limited design of the sectoral sanctions did not necessarily result in a rapid
disruption in business operations, particularly as oil prices rose. Despite sectoral sanctions,
Russian energy firms largely have been able to carry on business as normal.147 Russian oil
production reached record highs in 2018, despite restrictions on access to Western technology for
certain oil exploration projects.148 Russian oil exports to the United States have grown.149
Second, the Russian government has implemented various measures to support some sanctioned
firms. The support measures include central bank purchases of sanctioned banks’ debt, granting
government contracts to sanctioned firms, and recapitalizing sanctioned banks.150 More broadly,
the government created a department within the Finance Ministry to liaise with sanctioned
businesses, study their challenges, and draft government proposals for support.151 Although it is

144 Ahn and Ludema, “The Sword and the Shield,” 2020 (footnote 1); and Todd Prince, “Western Sanctions Have Had
‘Outsized Impact’ on Russian Companies, Economist Says,” RFE/RL, December 8, 2020.
145 Moscow Times, “Sanctions Hit Profits at Russian Defense and Technology Giant Rostec,” July 22, 2015; Chris
Isidore and Matt Egan, “ExxonMobil Drops Out of Russian Joint Venture Due to Sanctions,” CNN, March 1, 2018; and
Elena Holodny, “Russian Oil Behemoth Rosneft Reportedly Suspends an Oil Project in the Black Sea Because of
Western Sanctions,” Business Insider, October 30, 2017.
146 RFE/RL, “Q&A: Ex-White House Official Says New Russia Sanctions Will Have ‘Marginal, If Any, Impact,’”
March 15, 2018.
147 Henry Foy, “Russian Energy Groups Largely Unscathed by Western Sanctions,” Financial Times, March 15, 2018.
148 Vladimir Soldatkin, “Russian Oil Output Reaches Record High in 2018, Reuters, January 2, 2019..
149 Eklavya Gupte, “Analysis: US Reliance on Russian Oil Hits Record High Despite Souring Ties,” S&P Global, April
16, 2021.
150 See, for example, Bud Coote, “Impact of Sanctions on Russia’s Energy Sector,” Atlantic Council, March 2018;
Leonid Bershidsky, “Some Sanctioned Russian Firms Thrive on Adversity,” Bloomberg, May 8, 2018; Henry Foy,
“Russia: Adapting to Sanctions Leaves Economy in Robust Health,” Financial Times, January 29, 2020; and Moscow
Times
, “Russian State Firms Allowed to Hide Public Contracts as U.S. Sanctions Loom, November 30, 2021.
151 Olga Tanas and Katia Dmitrieva, “Russia’s Sanctioned Companies Seek $1.6 Billion in State Support,” Bloomberg,
April 20, 2018.
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difficult to find a precise quantitative estimate of the extent to which the Russian government has
used resources to shield firms from sanctions, such support shifts the cost of sanctions from the
targeted firms to the government.
Third, some Russian firms have minimized the sanctions’ impact by pursuing import substitution
policies and forging alternative economic partnerships. The Russian government has found
alternative suppliers for its military modernization, particularly from China, South Korea, and
Southeast Asia. Russian energy firms have concluded a number of corporate agreements with
Chinese and Saudi companies following the imposition of sanctions.152
The extent to which Russia can successfully execute a “pivot to China” and other non-Western
sources of financing, investment, and trade should not be overstated, however. CRIEEA’s
sanctions against third parties that engage in significant transactions with Russia’s defense and
intelligence sectors, as well as CRIEEA’s introduction of a policy option to impose secondary
sanctions against those that engage in significant transactions with sanctioned Russian individuals
and firms more generally, means that these alternatives remain risky and uncertain.
Impact on Russian Government Finances
U.S. sanctions on transactions related to Russian sovereign debt strive to make it more difficult,
and expensive, for the Russian government to borrow from international capital markets. The
Russian government, like many other governments, raises money from international investors by
selling bonds. In August 2019, the United States imposed restrictions on some U.S. transactions
in Russian sovereign bonds (see “Use of a Chemical Weapon,” above) and tightened these
restrictions in April 2021. U.S. sanctions prohibit U.S. investors from purchasing Russian bonds
when they are first sold (primary market transactions). Russian bonds, like other bonds, are
frequently traded by investors, and sanctions permit U.S. investors to buy and sell Russian bonds
after the initial bond auction (secondary market transactions).
Some evidence suggests sanctions have impacted the market for Russian bonds. Tighter sanctions
on Russian bonds in April 2021 caused foreign investors’ holdings of Russian government debt to
fall below 20% for the first time in six years.153 Additionally, the Bank of Russia canceled several
bond auctions in 2020 and 2021 due to insufficient bids, although it is unclear whether sanctions
or other factors (such as rising interest rates in advanced economies) are the underlying cause.154
The impact of restrictions on trade and investment in Russian sovereign debt is mediated by two
factors. First, these sanctions restrict specifically the initial sale of the bond, while permitting all
subsequent transactions during the bond’s term to maturity, which can exceed 10 years. This
means that the restriction against U.S. investors owning Russian bonds exists for a relatively
small portion of the bond’s lifespan. Second, the Russian government has strong public finances
and is generally not reliant on international investors to finance its budget. The government has

152 Richard Connolly and Philip Hanson, “Import Substitution and Economic Sovereignty in Russia,” Chatham House,
June 2016; Paul Mcleary, “Did Western Sanctions Actually Help the Russian Military?” Foreign Policy, January 23,
2017; Henry Foy, “Russia Turns to New Friends from China and the Middle East,” Financial Times, October 11, 2017;
Maria Shagina, Drifting East: Russia’s Import Substitution and Its Pivot to Asia, Center for Eastern European Studies,
April 2020; and Alexander Gabuev, “As Russia and China Draw Closer, Europe Watches with Foreboding,” Carnegie
Moscow Center, March 19, 2021. Also see CRS Report R46937, Russian Arms Sales and Defense Industry, by Andrew
S. Bowen.
153 Jake Cordell, “Sanctions Threat Pushes Foreign Share of Russian Debt to 6-Year Low,” Moscow Times, April 6,
2021.
154 Bank of Russia, “Bank of Russia Bond Auction Results,” accessed December 2021.
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low levels of debt, large reserve holdings, and a large domestic market for Russian bonds (i.e.,
Russian investors willing to purchase government bonds). In April 2021, U.S. investors
reportedly held about 7% of outstanding Russian sovereign bonds denominated in rubles.155
Russia’s De-Dollarization Efforts
The dol ar has served as the world's dominant reserve currency since World War II. It is the primary currency
used in cross-border transactions, held by central banks in reserves, and traded in foreign exchange markets. The
role of the dol ar reflects global confidence in the U.S. Federal Reserve as an institution and the U.S. economy and
financial markets more generally.
Russia has long sought to reduce its reliance on the U.S. dol ar, with the government accelerating its efforts
fol owing the expansion of U.S. sanctions in 2014. Taking a multipronged approach, the Russian government has,
with varying degrees of success, sought to reduce the share of central bank foreign exchange reserves held in
dol ars, reduce dol ar-denominated assets in its sovereign wealth fund, conclude agreements with other countries
to conduct trade in national currencies, and develop alternative payment systems that are not centered on the
dol ar.
Russian President Vladimir Putin has acknowledged that Russia wil not be able to completely de-dol arize and
referred to the dol ar as a “universal global currency.” However, if Russia and other countries, including China,
successful y pivot from the U.S. dol ar, this could have implications for U.S. economic and foreign policy interests.
Source: TASS Russian News Agency, “US Policy Undermines Dol ar’s Position as Reserve Currency—Putin,”
November 30, 2021. For more, see CRS In Focus IF11885, De-Dollarization Efforts in China and Russia, by Rebecca
M. Nelson and Karen M. Sutter.
Outlook
The United States and its allies have sustained sanctions on Russia since its 2014 invasion of
Ukraine, and these sanctions are supported on a bipartisan basis in Congress. As the United States
and other countries consider the possibility of new sanctions on Russia, debates about the impact
and effectiveness of existing sanctions persist. Despite almost eight years of escalating sanctions,
Russia has deepened its hold over Ukraine’s occupied Crimea region and separatist regions in
eastern Ukraine. Russia has extended military operations to nearby waters and has engaged in a
buildup of military forces near the Ukrainian border. Russian officials have intimated that Russia
could take further military action in Ukraine in pursuit of Russia’s national security interests.
The United States and other countries also have continued to document multiple incidents of
Russian malicious cyber-enabled activities and influence operations worldwide. The United
States and its allies have determined that Russian agents used lethal nerve agents to attack
opponents in the UK and in Russia. Russia continues to be an influential supporter of the Syrian
and Venezuelan governments and has deployed mercenaries accused of human rights abuses to
multiple conflict zones.
Some observers argue sanctions have restrained Russia somewhat or that the imposition of
sanctions is an appropriate foreign policy response regardless of immediate effect.156 Others are
skeptical that sanctions can produce desired changes in Russian behavior, at least without the use

155 Peter S. Goodman, Jack Ewing, and Matt Phillips, “Sanctions on Russian Debt are Called a ‘First Salvo’ that Sends
a Message,” New York Times, April 15, 2021.
156 Masha Gessen, “The Moral Case for Sanctions Against Russia,” New Yorker, April 6, 2018; and Nigel Gould-
Davies, “Sanctions on Russia Are Working,” Foreign Affairs, August 22, 2018.
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of other policy tools.157 Observers stress the importance of strengthening sanctions enforcement
and coordinating with U.S. allies and partners.158
Looking ahead, the United States and its allies have said they would consider new sanctions on
Russia in response to Russia’s military buildup near and in Ukraine. On December 7, 2021,
President Biden held a video conference with President Putin in which he “made clear that the
U.S. and our Allies would respond with strong economic and other measures in the event of
military escalation” in Ukraine.159 On December 12, 2021, Secretary Blinken joined the six other
Group of Seven (G7) foreign ministers and the EU High Representative for Foreign Affairs and
Security Policy in asserting that “Russia should be in no doubt that further military aggression
against Ukraine would have massive consequences and severe cost in response.”160
U.S. officials reportedly have conveyed examples of the kinds of additional sanctions under
consideration, including greater restrictions on transactions with Russian financial institutions and
U.S. technology exports. Some observers speculate that additional sanctions are possible,
including sanctions targeting Russia’s energy sector, secondary market transactions in Russian
sovereign debt, or Russia’s participation in international financial messaging services.161
With regard to Russia’s Nord Stream 2 natural gas pipeline to Germany, U.S. officials have said it
would “be difficult to see gas flowing through” the pipeline in the event of further Russian
aggression against Ukraine.162 German officials have not explicitly said Nord Stream 2 would be
impacted. They have said, however, they would uphold a joint pledge with the United States “to
limit Russian export capabilities to Europe in the energy sector, including gas, and/or in other
economically relevant sectors” should Russia “commit further aggressive acts against
Ukraine.”163

157 Andrea Kendall-Taylor, “U.S. Russia Policy: Moving Beyond Sanctions,” Center for a New American Security,
January 23, 2019; and Maria Shagina, “Toward a Trans-Atlantic Strategy on Russia Sanctions,” War on the Rocks,
December 6, 2021.
158 Anders Aslund and Maria Snegovaya, The Impact of Western Sanctions on Russia and How They Can Be Made
Even More Effective
, Atlantic Council, May 2021.
159 White House, “Readout of President Biden’s Video Call with President Vladimir Putin of Russia,” December 7,
2021.
160 U.S. Department of State, “G7 Foreign Ministers’ Statement on Russia and Ukraine,” December 12, 2021.
161 Paul Sonne, Ellen Nakashima, and Michael Birnbaum, “Amid Ukraine Invasion Scare, U.S. and Europe Lean on
Sanctions Threat to Stop Putin,” Washington Post, December 22, 2021; and David E. Sanger and Eric Schmitt, “U.S.
Details Costs of a Russian Invasion of Ukraine,” New York Times, January 8, 2022.
162 U.S. Department of State, “Secretary Antony J. Blinken and German Foreign Minister Annalena Baerbock at a Joint
Press Availability,” January 5, 2022.
163 U.S. Department of State, “Joint Statement of the United States and Germany on Support for Ukraine, European
Energy Security, and our Climate Goals,” July 21, 2022.
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Appendix A. Legislative Abbreviations and
Short Titles
CAATSA:
Countering America’s Adversaries Through Sanctions Act (P.L. 115-44)
CBW Act: Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (P.L.
102-182, Title III; 22 U.S.C. 5601 et seq.)
CRIEEA: Countering Russian Influence in Europe and Eurasia Act of 2017, as amended (P.L.
115-44, Title II; 22 U.S.C. 9501 et seq.)
Global Magnitsky Act: Global Magnitsky Human Rights Accountability Act (P.L. 114-328, Title
XII, Subtitle F; 22 U.S.C. 2656 note)
IEEPA: International Emergency Economic Powers Act (P.L. 95-223; 50 U.S.C. 1701 et seq.)
INKSNA: Iran, North Korea, and Syria Nonproliferation Act, as amended (P.L. 106-178; 50
U.S.C. 1701 note)
NEA: National Emergencies Act (P.L. 94-412; 50 U.S.C. 1601 et seq.)
PEESA: Protecting Europe’s Energy Security Act of 2019 (P.L. 116-92, Title LXXV; 22 U.S.C.
9526 note)
Sergei Magnitsky Act: The Sergei Magnitsky Rule of Law Accountability Act of 2012 (P.L. 112-
208, Title IV; 22 U.S.C. 5811 note)
SSIDES: Support for the Sovereignty, Integrity, Democracy, and Economic Stability of Ukraine
Act of 2014, as amended (P.L. 113-95; 22 U.S.C. 8901 et seq.)
UFSA: Ukraine Freedom Support Act of 2014, as amended (P.L. 113-272; 22 U.S.C. 8921 et
seq.)
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Appendix B. U.S. Sanctions on Russia
Table B-1. U.S. Sanctions on Russia for Which Designations Have Been Made
Objectionable
Date of Authority
Targets
Designations and
Behavior and
Other Actions
Authoritiesa
(as of 1/15/2022)
Invasion of Ukraineb



E.O. 13660; Countering
3/6/2014
Those responsible for
128 individuals, 24 entities
Russian Influence in
(codified 8/2/2017)
undermining Ukraine’s
Europe and Eurasia Act of
democracy; threatening its
2017 (P.L. 115-44, Title II;
peace, security, stability,
22 U.S.C. 9522)
sovereignty, or territorial
integrity; misappropriating
assets; and/or il egally
asserting government
authority.
E.O. 13661; P.L. 115-44
3/17/2014
Russian government officials; 109 individuals, 78
(codified 8/2/2017)
those operating in Russia’s
entities, 3 aircraft, 1
arms or related materiel
vessel
sector; entities owned or
control ed by a senior
Russian government official;
those acting on behalf of, or
materially assisting or
supporting, a senior Russian
government official.
E.O. 13662; P.L. 115-44
3/20/2014
Entities and individuals
290 entities (SSI);
(codified 8/2/2017)
operating in specified sectors 6 individuals, 13 entities
of the Russian economy.
(SDN)
Four Treasury directives
specify financial services,

energy (including deepwater,
Arctic offshore, and shale oil
development projects), and
defense.
E.O. 13685; P.L. 115-44
12/19/2014
Those engaging in new
75 entities, 10 individuals,
(codified 8/2/2017)
investment, trade, and
7 vessels
related economic activities
with the occupied Crimea
region of Ukraine.
Malicious Cyber-



Enabled or Intelligence
Activities
c
E.O. 13694, as amended
4/1/2015
Those engaged in malicious
73 individuals, 58 entities,
by E.O. 13757; P.L. 115-
(amended on 12/28/2016; cyber-enabled activities,
3 aircraft, 1 vessel
44 (22 U.S.C. 9522)
including related to election
codified 8/2/2017)
interference, likely to result
in a significant threat to the
national security, foreign
policy, or economic health
or financial stability of the
United States.
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Objectionable
Date of Authority
Targets
Designations and
Behavior and
Other Actions
Authoritiesa
(as of 1/15/2022)
P.L. 115-44 (§224); 22
8/2/2017
Those engaged in activities
22 individuals, 10 entities
U.S.C. 9524; E.O. 13849
on behalf of the Russian
government to undermine
cybersecurity against any
person, including a
democratic institution, or
government.
P.L. 115-44 (§231); 22
8/2/2017
Those that engage in
5 individuals, 2 entities
U.S.C. 9525; E.O. 13849
significant transactions with (additionally, 5 of 12
persons that are part of, or
sanctions as listed in 22
operate for or on behalf of, U.S.C. 9529)
Russia’s defense and
intelligence sectors.
E.O. 13848
9/12/2018
Foreign persons that have
39 individuals, 29 entities,
engaged in, sponsored,
3 aircraft, 1 vessel
concealed or otherwise
been complicit in foreign
interference in a United
States election.
E.O. 14024
4/15/2021
Those engaged in malicious
2 individuals, 9 entities
cyber-enabled activities,
election interference, or the
undermining of democratic
processes or institutions on
behalf of the Russian
government; those operating
in Russia’s technology sector
or its defense or related
materiel sector; Russian
government officials.
Use of a Chemical or



Biological Weapon
Chemical And Biological
12/4/1991
Any foreign government that Export restrictions on
Weapons Control and
has used chemical or
U.S. Munitions List items
Warfare Elimination Act
biological weapons in
and national-security
of 1991 (CBW Act; P.L.
violation of international law; sensitive goods or
102-182, Title III; 22
used lethal chemical or
technologies (the
U.S.C. 5601 et seq.)
biological weapons against its Commodity Control List);
own nationals; or made
termination of arms sales
substantial preparations to
and foreign military
engage in such activities.
financing; denial of U.S.
government credit, credit
guarantees, or other
financial assistance;
termination of foreign
assistance.
Prohibits U.S. banks from
lending non-ruble
denominated funds to the
Russian state and
participating in the
primary market for non-
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Objectionable
Date of Authority
Targets
Designations and
Behavior and
Other Actions
Authoritiesa
(as of 1/15/2022)
ruble denominated bonds
issued by the Russian
state.
Restricts export licenses
for goods control ed for
dual-use chemical and
biological applications.
Waiver authority invoked
to continue foreign
assistance; exports
related to government
space cooperation; and
export licensing in specific
categories related to civil
aviation safety, U.S. and
foreign whol y owned
subsidiaries operating in
Russia, and deemed
export licenses.
Human Rights Abuses



and Corruptiond
Sergei Magnitsky Rule of
12/14/2012
Those responsible for the
55 individuals
Law Accountability Act of
detention, abuse, or death of
2012 (P.L. 112-208, Title
Sergei Magnitsky, or who
IV; 22 U.S.C. 5811 note)
covered up related crimes,
or those who financially
benefitted from the related
criminal conspiracy or are
responsible for human rights
abuses against individuals
seeking to expose il egal
Russian government activity
or to exercise and defend
human rights and freedoms.
Global Magnitsky Human 12/23/2016
Those responsible for
8 individuals, 6 entities
Rights Accountability Act (E.O. issued on 12/20/2017) human rights abuses against
(P.L. 114-328, Title XII,
foreign persons seeking to
Subtitle F; 22 U.S.C. 2656
expose il egal government
note); E.O. 13818
activity or defending human
rights and freedoms and
those engaged in acts of
significant corruption.
Support for the
4/3/2014, amended 8/2/2017 Foreign persons for
2 individuals, 1 entity
Sovereignty, Integrity,
committing serious human
Democracy, and
rights abuses in territories
Economic Stability of
forcibly occupied or
Ukraine Act of 2014
control ed by Russia.
(SSIDES; P.L. 113-95), as
amended by P.L. 115-44
(§228); 22 U.S.C. 8910
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Objectionable
Date of Authority
Targets
Designations and
Behavior and
Other Actions
Authoritiesa
(as of 1/15/2022)
Energy Exports as a



Coercive or Political
Tool
e
P.L. 115-44 (§232); 22

Individuals and entities for
1 individual, 1 entity
U.S.C. 9526
investing or engaging in trade
valued at $1 mil ion, or
cumulatively at $5 mil ion
over 12 months, that
enhances Russia’s ability to
construct energy export
pipelines (discretionary).
Protecting Europe’s

Foreign persons that have
8 entities, 17 vessels
Energy Security Act of
sold, leased, provided, or
2019 (PEESA; P.L. 116-92,
facilitated the provision of
Title LXXV; 22 U.S.C.
vessels for the purpose of
§9526 note); E.O. 14039
subsea pipe-laying activities
related to the construction
of Nord Stream 2 and
TurkStream, or any
successor pipeline, or that
have provided underwriting
services or insurance, or
certain upgrades or
installation services.
Weapons Proliferationf


E.O. 13382
6/28/2005
Foreign persons engaged in
14 individuals, 17 entities
activities that materially
contribute to the
proliferation of weapons of
mass destruction or their
means of delivery.
Iran, North Korea, and
3/14/2000
Foreign persons who engage Export restrictions on 10
Syria Nonproliferation
(amended on 11/22/2005
in weapons trade or trade
entities
Act, as amended
and 10/13/2006)
that might materially
(INKSNA, P.L. 106-178;
contribute to Iran, North
50 U.S.C. 1701 note)
Korea, or Syria developing
or gaining access to a
weapon of mass destruction
or cruise or ballistic missile
system.
Export Controls Act of
8/3/2018 (continuing earlier Foreign persons suspected
Export restrictions on
2018 (P.L. 115-232, Title
authorities)
of U.S. export violations
individuals and entities
XVII, Part I; 50 U.S.C.
related to the procurement
4801 et seq.), to the
and delivery of items to
extent it continues export
Russia for military-related
controls and regulations
and other governmental or
issued under the Export
related end uses.
Administration Act of
1979 (P.L. 96-72; 50
U.S.C. 4601 et seq.)
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Objectionable
Date of Authority
Targets
Designations and
Behavior and
Other Actions
Authoritiesa
(as of 1/15/2022)
Trade with North



Koreag
E.O. 13722
3/18/2016
Those who trade in metals,
3 individuals, 4 entities
graphite, coal, or software in
a way that benefits the
government of North Korea;
those who engage in the
exportation of workers from
North Korea.
E.O. 13810
9/20/2017
Those who engage in at least 4 entities, 6 vessels
one significant trade
transaction with North
Korea; those who operation
in the information
technology sector of North
Korea; foreign financial
institutions that conduct or
facilitate transactions with
North Korean designees or
any significant transaction in
connection with trade with
North Korea.
Support to Syriah



E.O. 13582
8/17/2011
Those providing material
13 individuals, 8 entities
support and services to the
government of Syria.
Support to Venezuelai



E.O. 13850
11/1/2018
Foreign financial institutions 1 individual, 4 entities, 2
providing material support
vessels
and services to the
government of Venezuela.
Transnational Crime



and Terrorismj
E.O. 13581
7/24/2011
Foreign persons that
15 individuals, 6 entities
constitute a significant
transnational criminal
organization and those who
support them.
E.O. 13224
9/23/2001
Foreign persons who
12 individuals, 2 entities
commit acts of terrorism
that threaten the security of
U.S. nationals or of U.S.
national security, foreign
policy, or economy.
Source: Congressional Research Service (CRS).
Notes: Individuals and entities on the U.S. Department of the Treasury’s Office of Foreign Assets Control
(OFAC) Special y Designated Nationals and Blocked Persons List (SDN) have their assets blocked, and U.S.
persons generally are prohibited from engaging in transactions with them.
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With entities on OFAC’s Sectoral Sanctions Identifications List (SSI), U.S. persons are prohibited from engaging
in certain types of transactions (related to financing, investment, and/or trade, depending on the economic sector
of the target).
a. Executive orders (E.O.s) shown in this column are based on authorities provided to the President to (1)
declare that there exists a national emergency (National Emergencies Act; P.L. 94-412; 50 U.S.C. 1601 et
seq.) that threatens the national security, foreign policy, or economy of the United States and “which has its
source in whole or substantial part outside the United States” and (2) to use economic tools to address the
threat (International Emergency Economic Powers Act; P.L. 95-223; 50 U.S.C. 1701 et seq.). E.O.s based on
these authorities are generally codified at 50 U.S.C. 1701 note. The President is required to renew annually
any E.O. that declares a national emergency.
b. In addition to listed SDN designations, the United States has imposed export restrictions on many entities
for activities related to Russia’s invasion of Ukraine. Most of these entities are on the SDN list. For a list of
SDN designees and entities on the SSI list, see Programs “UKRAINE-EO13660,” “UKRAINE-EO13661,”
“UKRAINE-EO13662,” and “UKRAINE-EO13685,” at https://sanctionssearch.ofac.treas.gov/. Entities subject
to export restrictions are on the Entity List (Supplement No. 4 to Part 744 of the Export Administration
Regulations). Other sanctions program lists are specified below.
c. For SDN designees, see Programs “CYBER2,” “CAATSA-RUSSIA,” “ELECTION-EO13848,” and “RUSSIA-
EO14024.”
d. For SDN designees, see Programs “MAGNIT,” “GLOMAG,” and “CAATSA-RUSSIA.”
e. For SDN designees, see Programs “CAATSA-RUSSIA,” “PEESA,” and “PEESA-EO14039.”
f.
For SDN designees, see Program “NPWMD.” Entities subject to INKSNA sanctions are available at
https://www.state.gov/wp-content/uploads/2021/08/MASTER-Sanctions-chart-8-16-21.pdf. Entities subject to
export restrictions are on the Entity List.
g. For SDN designees, see Programs “DPRK3” and “DPRK4.” Provisions referenced are those that have been
used to designate Russian nationals or those affiliated to Russian nationals, as identified by CRS.
h. For SDN designees, see Program “SYRIA.”
i.
For SDN designees, see Program “VENEZUELA-EO13850.”
j.
For SDN designees, see Programs “TCO” and “SDGT.” Designees are those identified by CRS as Russian
nationals or affiliated to Russian nationals.
Table B-2. U.S. Sanctions on Russia for Which Designations Have Yet to Be Made
Authority
Targets
Sanctions Action
Ukraine Freedom Support Act
Russian individuals and entities for
At least 3 of 9 sanctions as listed in
(UFSA; P.L. 113-272); 22 U.S.C.
conducting weapons transfers to
22 U.S.C. 8923(c)
8923(a)
Syria, Ukraine, Georgia, Moldova,
and potentially other countries.
UFSA; 22 U.S.C. 8923(b)(3)
Withholding by Gazprom of
Prohibition on investment in equity
significant natural gas supplies from
or debt of longer than 30 days
NATO member states or countries
maturity and at least 1 additional
such as Ukraine, Georgia, or
sanction as listed in 22 U.S.C.
Moldova.
8923(c)
UFSA, as amended by P.L. 115-44
Foreign individuals or entities for
At least 3 of 9 sanctions as listed in
(§225); 22 U.S.C. 8923(b)(1)
investing in deepwater, Arctic
22 U.S.C. 8923(c)
offshore, or shale oil projects in
Russia.
UFSA, as amended by P.L. 115-44
Foreign financial institutions for
Prohibition on the opening of
(§226); 22 U.S.C. 8924
facilitating significant transactions
correspondent or payable-through
related to or for (1) Russia’s
accounts in the United States and a
weapons transfers to Syria, Ukraine, prohibition or imposition of strict
Georgia, Moldova, and potentially
conditions on the maintenance of
other countries;
such accounts
(2) deepwater, Arctic offshore, or
shale oil projects in Russia; and
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Authority
Targets
Sanctions Action
(3) individuals and entities subject
to sanctions related to Russia’s
invasion of Ukraine.
Support for the Sovereignty,
Russian government officials, family
Asset blocking, prohibitions against
Integrity, Democracy, and
members, and close associates for
transactions with U.S. persons, visa
Economic Stability of Ukraine Act
acts of significant corruption.
denials
of 2014 (SSIDES; P.L. 113-95), as
amended by P.L. 115-44 (§227); 22
U.S.C. 8908
SSIDES, as amended by P.L. 115-44
Foreign individuals and entities for
Asset blocking, prohibitions against
(§228); 22 U.S.C. 8909
violating Ukraine- or cyber-related
transactions with U.S. persons, visa
sanctions or facilitating significant
denials
transactions for individuals, their
family members, and entities subject
to sanctions on Russia.
P.L. 115-44 (§233); 22 U.S.C. 9527
Individuals and entities for making
At least 5 of 12 sanctions as listed in
or facilitating investments of
22 U.S.C. 9529
$10 mil ion or more that contribute
to Russia’s privatization of state-
owned assets “in a manner that
unjustly benefits” government
officials, relatives, or associates.
P.L. 115-44 (§234); 22 U.S.C. 9528
Foreign individuals and entities for
Asset blocking, prohibitions against
significant support for Syria’s
transactions with U.S. persons, visa
acquisition or development of a
denials
variety of advanced or prohibited
weapons and defense articles.
E.O. 14024
Those engaged in transnational
Asset blocking, prohibitions against
corruption; the unlawful kil ing or
transactions with U.S. persons, visa
harming of U.S. persons or U.S. ally
denials
or partner nationals; activities that
“undermine the peace, security,
political stability, or territorial
integrity of the United States, its
allies, or its partners”; and the
circumvention of U.S. sanctions.
Russian persons who support
governments subject to U.S.
sanctions or who disrupt energy
supplies to Europe or Asia.
Source: CRS.
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Appendix C. Sanctions in Selected Russia-Related
Legislation

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.)

 New sanctions against individuals and entities for
o Violence and human rights abuses during antigovernment protests in Ukraine in
2013-2014 and for having undermined Ukraine’s peace, security, stability,
sovereignty, or territorial integrity (§8907).
o Helping to evade sanctions provided for in Ukraine-related or cyber-
related E.O.s, SSIDES, or UFSA, or that facilitate significant
transactions for individuals, their family members, and entities subject to
U.S. sanctions imposed with respect to Russia (as amended; §8909)
o Serious human rights abuses in territories forcibly occupied or otherwise
controlled by Russia (as amended; §8910)
 New sanctions against Russian government officials, family members, and close
associates for acts of significant corruption in Ukraine (§8907).
 Mandatory sanctions against Russian government officials, family members,
and close associates for acts of significant corruption in Russia or elsewhere (as
amended; originally discretionary for acts of significant corruption in Russia)
(§8908)
Ukraine Freedom Support Act of 2014, as amended (UFSA; P.L. 113-
272; 22 U.S.C. 8921 et seq.)

 New sanctions against Russian state arms exporter Rosoboronexport and against Russian
entities that transfer weapons to Syria or, without consent, Ukraine, Georgia, Moldova,
and potentially other countries that the President designates as countries of significant
concern (§8923).
 Mandatory sanctions against foreign individuals and entities that make significant
investments in deepwater, Arctic offshore, or shale oil projects in Russia (as amended;
originally discretionary) (§8923).
 Mandatory sanctions against foreign financial institutions that facilitate significant
transactions related to defense- and energy-related transactions subject to UFSA
sanctions, or for individuals and entities subject to sanctions under UFSA or Ukraine-
related E.O.s (as amended; originally discretionary) (§8924).
 Contingent sanctions against state-owned energy company Gazprom, if it is found to
withhold significant natural gas supplies from NATO member states or countries such as
Ukraine, Georgia, and Moldova (§8923).
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Countering Russian Influence in Europe and Eurasia Act of 2017, as
amended (CRIEEA; P.L. 115-44, Title II; 22 U.S.C. 9501 et seq.)

 Codification of Ukraine-related E.O.s 13660, 13661, 13662, and 13685 (§9522)
 Codification of cyber-related E.O. 13694, as amended by E.O. 13757 (not
Russia-specific) (§9522)
 Modifications to E.O. 13662 directives to reduce short-term lending terms to
financial services and energy companies and to expand restrictions on
transactions by U.S. individuals and entities related to the development of
deepwater, Arctic offshore, and shale oil projects in which identified Russian
entities have an ownership interest of at least 33% or a majority of voting
interests (§9523)
 New sanctions against individuals and entities for
 Engaging in or supporting significant activities that undermine cybersecurity
on behalf of the Russian government (§9524)
 Engaging in significant transactions with Russia’s defense and intelligence
sectors (§9525)
 Making or facilitating investments of $10 million or more that contribute to
Russia’s privatization of state-owned assets “in a manner that unjustly
benefits” government officials, relatives, or associates (§9527)
 New sanctions against foreign individuals and entities for significant support
for Syria’s acquisition or development of a variety of advanced or prohibited
weapons and defense articles (not Russia-specific) (§9528)
 Discretionary authority to impose sanctions against individuals and entities that
invest or engage in trade valued at $1 million, or cumulatively at $5 million over
12 months, that enhances Russia’s ability to construct energy export pipelines
(§9526)
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Appendix D. U.S. and EU Sectoral Sanctions
Table D-1. U.S. and EU Sectoral Sanctions
United States
European Union (EU)
(E.O. 13662, Directives 1-4)
(Council Decision 2014/512/CFSP)
Financial Sector
Gazprombank (+ affiliated)
Gazprombank
Rosselkhozbank (+ affiliated)
Rosselkhozbank
Sberbank (+ affiliated)
Sberbank
VEB (+ affiliated)
VEB
VTB Bank (+ affiliated)
VTB Bank

Defense Sector
Rostec (+ affiliated)
Oboronprom (Rostec subsidiary)
United Aircraft Corporation
Uralvagonzavod (Rostec subsidiary since end of 2016)

Energy Sector
Gazpromneft
Gazpromneft
Rosneft (+ affiliated)
Rosneft
Transneft
Transneft
Novatek (+ affiliated)

Arctic Offshore, Deepwater, and Shale Oil Projects
Gazprom (+ affiliated)
Companies not specified.
Gazpromneft

Lukoil
Rosneft (+ affiliated)
Surgutneftegaz (+ affiliated)
Source: CRS.
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Appendix E. Russian Firms and U.S. Sanctions
Table E-1. Russia’s Largest Firms and U.S. Sanctions
Rank
Company Name
Sector
SDN
SSI (Debt
SSI (Oil
(Blocking)
and/or
Project)
Sanctions
Equity)
Sanctions
Sanctions
1
Gazprom
Oil and gas


X
2
Rosneft
Oil and gas

X
X
3
Lukoil
Oil and gas


X
4
Sberbank
Finance

X

5
Russian Railways
Transport



6
X5 Retail Group
Trade



6 (tie)
Rostec
Investments

X

7
Magnit
Trade



8
VTB
Finance

X

9
Rosatom
Atomic industry



9 (tie)
SAFMAR
Investments



10
Nornickel
Metals and mining



11
Surgutneftegas
Oil and gas


X
12
Rosseti
Power engineering



13
Inter RAO
Power engineering



14
Transneft
Oil and gas

X

15
Rosoboronexport
Distribution
X
X

16
Mercury Retail Group
Trade



17
Megapolis Group
Distribution



17
En+
Investments



(tie)
Source: CRS analysis of data published by Russian media outlet RBC (https://www.rbc.ru/rbc500/) on the largest
firms in Russia and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) Special y
Designated Nationals and Blocked Persons (SDN) and Sectoral Sanctions Identifications (SSI) sanctions lists. Data
accessed on November 19, 2019.
Notes: Individuals and entities on OFAC’s SDN list have their assets blocked, and U.S. persons are generally
prohibited from engaging in transactions with them.
With entities on OFAC’s SSI list, U.S. persons are prohibited from engaging in certain types of transactions
(related to financing, investment, and/or trade, depending on the economic sector of the target).
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Author Information

Cory Welt, Coordinator
Rebecca M. Nelson
Specialist in Russian and European Affairs
Specialist in International Trade and Finance


Kristin Archick
Dianne E. Rennack
Specialist in European Affairs
Specialist in Foreign Policy Legislation




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Congressional Research Service
R45415 · VERSION 10 · UPDATED
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