The Office of Foreign Assets Control (OFAC) published Executive Order (E.O.) of April 6, 2022 “Prohibiting New Investment in and Certain Services to the Russian Federation in Response to Continued Russian Federation Aggression”, to ban all new investment in Russia by U.S. persons, wherever located. Similar to E.O.s 14066 and 14068 – which prohibit imports and exports of goods and services of certain products and categories involving Russia – this new E.O. also authorizes the Secretary of the Treasury to ban the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of any category of services. Further, OFAC issued 6 General Licenses that temporarily allow certain operations that would otherwise be prohibited under the new sanctions.
In addition, OFAC has blocked Public Joint Stock Company Sberbank of Russia (Sberbank) and 42 of its subsidiaries, which is uniquely important to the Russian economy, holding about a third of all bank assets in Russia. Sberbank is the largest financial institution in Russia and is majority-owned by the Government of the Russia (GoR). OFAC is also imposing full blocking restrictions on Joint Stock Company Alfa-Bank (Alfa-Bank) and 6 of its subsidiaries, Russia’s largest privately-owned financial institution and Russia’s fourth-largest financial institution overall.