On April 15, 2021, the White House and the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a package of economic sanctions targeting Russia, including expansive new legal authorities that would allow for the imposition of additional future sanctions on Russia in the technology sector and on Russian government bodies. OFAC has also issued expanded restrictions on participation in the primary market for Russian sovereign debt, and lending to the Russian government, by US financial institutions. In addition, OFAC blocked nearly 40 additional individuals and entities for “attempt[ing] to influence the 2020 [US] presidential election” and engaging in certain activities in Crimea. At the same time, the US Department of State announced the expulsion of 10 Russian diplomats.
The centerpiece of the package is Executive Order (“E.O.”) 14024, which, according to an OFAC press release, “elevates the [US] government’s capacity to deploy strategic and economically impactful sanctions to deter and respond to Russia’s destabilizing behavior.” As the first significant Russia sanctions action by the Biden Administration, E.O. 14024 appears to have been intended to send a strong signal to Russia, but without taking action at this stage that would be highly or disproportionately economically damaging. In taking this approach, it appears that the Administration has left open the possibility of an improvement in relations with Russia. Indeed, these sanctions were preceded by President Biden’s April 13th proposal of a possible summit with President Putin to “discuss the full range of issues facing the United States and Russia.”