Russia Sanctions: Comments on OFAC's 24 Feb Actions

Comments from FRA Partner Charlie Steele

This new round, as promised, ratchets things up substantially. Treasury called them "unprecedented," and that's accurate, as far as their scope and magnitude. But it won't be clear for at least a while how much pain it inflicts, and whether Putin can tolerate the pain.

These sanctions are focused mainly on the banking and financial sector, which is of course critically important to Russia. Several observers have noted that these measures don't go after Russia's energy sector, but that could well be next, or soon. President Biden has extremely broad authority here, not only to impose sanctions but also to devise and craft new types of sanctions. The only real limitation is how imaginative the government's sanctions people are - and they're pretty imaginative.

And of course there were sanctions on additional elites and their family members. I'd expect every new round to include more of those, until the US runs out of those targets.

The extensive new international sanctions against Russia in response to the situation in Ukraine are a reminder that sanctions compliance is a critical issue for financial and non-financial companies around the world. Learn more about FRA's expertise in this critical area.