On December 22, the US Treasury Department, Office of Foreign Assets Control (OFAC) designated 34 individuals and entities for sanctions under the Ukraine-Related Sanctions Regulations.  First, OFAC designated new Specially Designated Nationals (SDNs) based on their being owned by Gennady Timchenko, Arkady Rotenberg, Boris Rotenberg, Kalashnikov Concern, or Izhevsky Mekhanichesky Zavod JSC, all of whom were previously designated as SDNs; for their involvement in separatist activity in Ukraine; for their role as officials in the Yanukovych regime in Ukraine; or for their operations in the disputed Crimea region.  Additionally, OFAC designated several entities for sectoral sanctions based on their ownership by VTB Bank, Sberbank, and Rostec, all of which were designated previously.

Additionally, on December 28, the US Commerce Department, Bureau of Industry and Security (BIS) issued guidance regarding the scope of export restrictions imposed on Russian entities designated on the BIS Entity List under Section 746.5 of the Export Administration Regulations (known as the “Russian Industry Sector Sanctions”).  BIS also made several new Entity List designations to be consistent with the OFAC designations.

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