1.On Monday April 28, the US imposed sanctions on

– an additional 7 Russian individuals and

– 17 Russian or Russian-owned companies.

2.All of these persons were added to the primary US sanctions list, the list of specially designated nationals, or ‘SDN’ list.

3.US persons are prohibited from dealing with any SDN, or any entity in which an SDN directly or indirectly owns 50% or more of the shares.

4.In addition, US persons must block (freeze) any funds or other assets in which any SDN or any such majority-owned entity has an interest, if those assets are in the possession or control of the US person.

5.The seven sanctioned individuals are Russian government officials of various ranks.

– One, Sergei Chemezov, is the Director General or CEO of a large state-owned manufacturing conglomerate, Rostec.

i. The US Treasury Department has made clear that Rostec “has not been sanctioned”.

– Another, Igor Sechin, is President and Chairman of the Management Board of Rosneft, one of Russia’s largest petroleum companies.

i. Chemezov is also a director of Rosneft.

ii. As with Rostec, the US Treasury has stated expressly that ‘Rosneft is a state-owned company and has not been sanctioned.’

6.The US Treasury has stated that the 17 sanctioned companies were selected because they are close to the Russian leadership, or persons already designated on that basis, and not for any direct involvement in eastern or southern Ukraine or Crimea. They consist of:

– InvestCapitalBank and SMP Bank,

i. two midsize Russian banks controlled by Arkady and Boris Rotenberg (two brothers sanctioned by the US in March).

ii. Reportedly each of the Rotenbergs holds 38% of the shares of SMP Bank.

iii. In March, OFAC confirmed that SMP Bank should not be considered blocked (sanctioned) by virtue of that shareholding.

iv. Thus, until its SDN listing on April 28, SMP Bank was not considered blocked under US sanctions.

– The Volga Group, located in Luxembourg and Russia, designated for being owned or controlled by Gennady Timchenko, who was sanctioned by the US in March.

i. Due to Timchenko’s interest in the Volga Group, it has generally been considered blocked since March.

ii. Also sanctioned were 10 companies in various business sectors owned or controlled by the Volga Group and Timchenko.

iv. These companies include the mid-sized Russian construction company Stroytransgaz Holding located in Cyprus, and four of its Russian affiliates.

– Stroygasmontazh (SGM Group), a gas pipeline construction company, designated for being owned or controlled by one of the Rotenberg brothers.

– Three financial sector companies owned or controlled by Bank Rossiya, which was sanctioned by the US in March.

i. Two are not well known, while JSB Sobinbank is a midsized Russian bank that has been generally considered blocked since March due to the reported Bank Rossiya ownership.