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Over the past week, the United States, European Union, United Kingdom, and other allies have imposed multi-lateral sanctions against Russia in response to its military invasion of Ukraine. First, on February 22, 2022, the U.S. imposed a full trade embargo in response to Russia’s decision to annex and recognize the Donetsk and Luhansk People’s Republics as independent states, as well as sanctions against two state-owned financial institutions. Second, on February 24, 2022, in response to Russia’s further invasion of Ukraine, the U.S. announced wide-ranging sanctions impacting the financial services sector of the Russian economy, which included new sanctions on numerous Russian financial institutions, as well as restrictions on transactions involving certain new debt or equity issuances. The U.S. also imposed sanctions against Belarus for its support of the Russian invasion of Ukraine. Third, on February 25, 2022, the U.S. imposed blocking sanctions against Vladimir Putin and certain other senior members of the Russian government. Finally, on February 28, 2022, the U.S. imposed sanctions against the Central Bank of Russia and the Russian Direct Investment Fund, among other actions.

In short, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), in implementing these new sanctions, has established a new sanctions program titled the “Russian Harmful Foreign Activities Sanctions” program. We provide additional details on the U.S.’s new sanctions below. Identifying information for those who have been sanctioned can be found on OFAC’s consolidated Sanctions List.

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Andrew Jacobson | Associate

A former enforcement attorney at the New York State Department of Financial Services (DFS), Andrew Jacobson represents individual and institutional clients at Seward & Kissel in connection with complex governmental investigations, regulatory probes, and related civil matters. While at the DFS, Andrew was involved in early cryptocurrency issues and brought some of the most significant enforcement actions for violations of U.S. economic sanctions and anti-money laundering laws.

Andrew has extensive experience advising on matters relating to U.S. economic sanctions, including those administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), and anti-money laundering laws. Andrew serves as Chair of the Export Controls, Sanctions, and Anti-Corruption Subcommittee of the International Bar Association, co-chair of the Virtual Commodity Association’s BSA/AML Committee, and is a member of the Digital Chamber of Commerce’s AML Task Force.

As a member of Seward & Kissel’s Blockchain and Cryptocurrency Group, Andrew regularly advises clients on all aspects of financial crimes compliance and licensing in the virtual asset industry, including:

  • OFAC and FinCEN regulatory requirements, including asset blocking and reporting obligations;

  • Unhosted wallets and risks to software providers and VASPs;

  • Privacy coins, mixers, and other external privacy mechanisms;

  • Technology and open-source user platforms;

  • Ransomware and other cyberattack-related ransom payments;

  • BitLicense and state licensing requirements; and

  • Counterparty due diligence and screening.

 

“This is certainly a lesson to senior management to take compliance seriously and that there are consequences for individuals who don’t follow the regulatory regime.”

Andrew’s thoughts on BitMEX indictment, as published in Law360 article “BitMEX Case Seen as Blessing in Disguise for Crypto Sector”