Sanctions Multilateralism on All fronts

Feb. 6, 2023
By: Marvin E. McPherson

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) continues to move against sanctions evaders. On February 1, 2023, OFAC listed full blocking sanctions against 22 individuals and entities across multiple countries related to a sanction’s evasion network, supporting Russia’s military-industrial complex.

OFAC’s updated sanctioned parties list centered around targeting those organizations and persons that have been utilizing proxies to circumvent U.S. sanctions to aid Russia’s military-industrial complex. Treasury in a statement announced that “Targeting proxies is one of many steps that Treasury and our coalition of partners have taken, and continue to take, to tighten sanctions enforcement against Russia’s defense sector, its benefactors, and its supporters.”

The Treasury is not the only faction interested in urging sanctions compliance. Latvia’s Prime Minister Krisjanis Karins in a recent news conference urged stricter governmental compliance of sanctions as “traders of all kinds are using Turkey, Kazakhstan and Armenia to evade European Union sanctions on Russia.” The Prime minister’s comments expound on a broader sentiment held by other EU countries. The comments further signal a multilateral need for further sanctions compliance and enforcement.

Companies should prepare for stricter sanctions rules not only in the U.S but abroad as well. Sanctions audits and enforcement are likely to increase as the markers for sanctions success i.e., slowing Russia and China’s ability to invest in military advances, are not effectuating as the governments around the world intended.

If you have question regarding OFAC’s sanctions rules or would like help navigating the ever moving sanction prohibitions, please reach out to any of our attorneys if you have any questions.