On March 31, 2022, the Office of Foreign Assets Control issued a “Determination Pursuant to Section 1 of Executive Order 14024.”  This determination allows the Department of Treasury in conjunction with the Secretary of State to sanction any person who operates in the electronic, aerospace, and marine sectors of the Russian economy.  OFAC has not specially defined what it considers to be the “marine sector.”  Given the broad inclusion of additional industries subject to sanctions, we expect OFAC will specifically define the types of entities within each sector to be targeted.  We will continue to monitor OFAC guidance and provide updates as they become available.

To read a copy of the Department of Treasury Determination Click Here.

To read a copy of Executive Order 14024 Click Here.