Updated January 2017
List of Sanctioned Individuals and Entities from Russia (includes Crimea)
By Country
The USRBC has compiled a comprehensive list of Russian and Crimean individuals and entities sanctioned as of January 2016 related to the Ukraine crisis. The United States, EU, Canada, and Australia have imposed sanctions that consist of asset freezes, travel bans and the prohibition of financial transactions with designated
individuals and entities. A number of non-EU European countries have joined the EU sanctions. Japan has imposed visa bans and asset freezes as well as limited financial and dual-use sanctions. The United States and EU expanded their sanctions actions to include a prohibition on buying or selling new debt or equity with a
maturity of longer than 90 days (reduced to 30 days for some entities on September 12, 2014) with designated entities; bans on the sale of technologies and services for oil projects in deepwater, Arctic or shale; and prohibitions on dual-use and defense-related exports. Canada instituted a ban on the sale of technologies
used in oil exploration and production from Arctic, deepwater and shale reserves on December 19, 2014. A breakdown of these lists follows. Several other countries have also instituted sanctions in limited forms, including Norway, Iceland, Liechtenstein, and Switzerland.*
Terminology
SDN List: Specially-Designated Nationals List. This designation includes visa bans, asset freezes and a total prohibition on doing business with the listed entity or indival
SSI List: Sectoral Sanctions Identifications. This designation prohibits the issuance of debt or equity with a maturity of more than 30 days to a designated entity or individual as well as dual-use export prohibitions and prohibitions on the sale or transfer of certain energy sector technologies.
Total
U.S.
EU
Canada
RUS/Crimean Gov't. Officials
108
65
82
82
SDN List: Russian/Crimean Government Officials
LAST
FIRST
1
Abisov
Sergey
2
Aksyonov
Sergey
3
Alexseyev***
Vladimir
TOTALS
Other Russian Individuals
24
21
6
9
Russian/Crimean Entities
85
79
25
54
TITLE/REASON
Minister of Interior, Republic of Crimea
Acting Governor of Crimea
First Deputy Head, GRU (election Interference)
U.S.
Minister of Property of Crimea
State Duma Deputy
State Duma Deputy (Crimea)
First Deputy Minister of Defense
State Duma Deputy (Crimea)
Russia's Presidential Envoy to Crimea
State Duma Deputy (Crimea)
Defected from Ukrainian Navy to Crimean Armed
Forces
FSB Colonel General
Head of the People's Republic of Donetsk (Russian
national)
Minister of Energy of Crimea
Director, RF Federal Security Service (FSB)
Deputy Speaker of the Federation Council
Formerly the self-proclaimed Mayor of Sevastopol in
Crimea
Member, RF State Duma
Minister of Economic Development of Crimea
First Deputy Chairman of the Committee on
International Affairs of the RF Federation Council
x
4
5
6
7
8
9
10
11
Anna
Babakov
Bakharev
Bakhin
Balbek
Belavantsev
Belik
Berezovsky
Anyukhina
Alexander
Konstantin
Arkady
Ruslan
Oleg
Dmitry
Denis
12
13
Beseda
Borodai
Sergey
Alexander
14
15
16
17
Borodulina
Bortnikov
Bushmin
Chaliy
Svetlana
Alexander
Evgeni
Aleksei
18
19
20
Degtyarev
Demidov
Dzhabarov
Mikhail
Valentin
Vladimir
21
22
Fradkov
Fursenko
Mikhail
Andrei
Director, RF Foreign Intelligence Service (SVR)
Aide to the President of the Russian Federation
23
24
25
26
Galkin
Gerasimov
Gizunov***
Glazyev
Aleksandr
Valery
Sergey
Sergey
Commander of the Southern Military District
First Deputy Minister of Defense
Deputy Head, GRU (election interference)
Aide to the President of the Russian Federation
27
Gromov
Alexey
28
29
Gryzlov
Ignatenko
Boris
Vitaly
30
Ivanov
Sergei
First Deputy Chief of Staff of the Presidential
Administration
Permanent Member, RF Security Council
First Deputy Chairman of the Federation Council
Committee for Foreign Affairs
Chief of Staff of the Presidential Administration
x
x
x
EU
x
x
Canada
x
x
x
x
x
Switzerland
x
x
Liechtenstein
x
x
Australia
x
x
Japan
x
Norway
x
x
Albania
x
x
Iceland
x
x
Montenegro
x
x
Ukraine
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
1
31
32
Ivanov
Jarosh
Viktor
Petr
33
34
Kadyrov
Kalashnikov
Ramzan
Leonid
35
Kartopolov
Andrei
36
37
Kiviko
Klishas
Irina
Andrei
38
39
40
41
Kobzon
Konstantinov
Korobov***
Kostyukov***
Iosif
Vladimir
Igor
Igor
Minister of Finance of Crimea
Chairman of the Federation Council Committee on
Constitutional Law
Member, RF State Duma
Speaker of the Crimean Parliament
Head, GRU (election interference)
First Deputy Head, GRU (election Interference)
42
Kovatidi
Olga
Member of the Federation Council, from Crimea
43
Kozak
Dmitry
Deputy Prime Minister of the Russian Federation
44
45
Kozenko
Kozhin
Andrey
Vladimir
46
Kozyura
Oleg
47
48
Kulikov
Kulishov
Valery
Vladimir
49
50
Lebedev
Lebedev
Igor
Oleg
51
52
53
Levichev
Malyshev
Margelov
Nikolai
Mikhail
Mikhail
54
55
56
57
Matviyenko
Medvedev
Melnikov
Menyailo
Valentina
Valery
Ivan
Sergei
58
Mironov
Sergei
59
Mizulina
Yelena
60
Muradov
Georgiy
61
62
63
64
65
66
67
Murov
Naryshkin
Naumets
Nazarov
Neklyudov
Neverov
Nikitin
Gen. Evgeniy
Sergei
Maj. Gen. Alexey
Mikhail
Dmitry
Sergei
Vladimir
68
69
70
Nosatov
Nurgaliev
Ozerov
Alexander
Rashid
Viktor
71
72
Palagin
Panteleev
Viktor
Oleg
73
74
Patrushev
Pligin
Nikolay
Vladimir
75
76
Poklonskaya
Polonsky
Natalia
Dmitry
Member of the RF Security Council
x
Acting Head of the Federal Migration Service Office
for Crimea
President, Republic of Chechnya
First Deputy Chairman, State Duma Committee on
Foreign Affairs
Deputy Head, Russian Armed Forces' General Staff
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
State Duma Deputy (Crimea)
Manager of Presidential Affairs of the Presidential
Administration
Acting Head of the Federal Migration Service Office
for Sevastopol
Deputy Commander of the Black Sea Fleet
First Deputy Director, RF Federal Security Service
(FSB); Chief, Border Guards Service
Deputy Speaker, RF State Duma
First Deputy Chairman, State Duma Committee on
Relations with CIS Countries
Deputy Speaker, RF State Duma
Chair of the Crimea Electoral Commission
Chairman of the Federation Council Committee for
Foreign Affairs
Federation Council Speaker
Chair of the Sevastopol Electoral Commission
First Deputy Speaker, RF State Duma
Acting governor of Sevastopol within annexed
Crimea
State Duma Deputy, Leader of the "A Just Russia"
faction
Chairman of the State Duma Committee on Family,
Women and Children's Issues
RF Presidential Plenipotentiary Representative of
Crimea
Director of Russia's Federal Protective Service
Speaker of the State Duma
Commander, 76th Airborne Division
Director, Investigative Committee Crimea
Deputy Minister of Interior of Crimea
Deputy Speaker of the State Duma
First Deputy Chairman, State Duma Committee on
Relations with CIS Countries
Deputy Commander of the Black Sea Fleet
Deputy Secretary, RF Security Council
Chairman of the Committee on Security and
Defense of the RF Federation Council
Head, FSB Directorate in Crimea
First Deputy Chairman, Committee on
Parliamentary Issues, RF Federation Council
Secretary, RF Security Council
Chairman of the State Duma Constitutional Law and
Nation Building Committee
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
Prosecutor of Crimea
Minister of Communications of Crimea
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
2
x
77
Pushkov
Aleksei
Rashkin
Rogozin
Ryzhkov
Savchenko
Savelyev
Valery
Dmitry
Nikolai
Svetlana
Oleg
Chairman of the State Duma Committee on
International Affairs Member, RF State Duma
Deputy Prime Minister
Federation Council Member
State Duma Deputy (Crimea)
Minister of Crimean Affairs
x
78
79
80
81
82
x
x
x
x
x
x
x
x
83
84
85
86
Sergun
Shamanov
Shapovalov
Shchegolev
Lt. Gen. Igor
Vladimir
Oleg
Igor
Deputy Chief of the General Staff of Russia
Commander of the Russian Airborne Troops
Minister of Justice of Crimea
Aide to the President of the Russian Federation
x
x
x
87
88
89
90
Sheremet
Shevchenko
Shperov
Shvetsova
Mikhail
Igor
Pavel
Ludmila
First Deputy Prime Minister of Crimea
Acting Prosecutor of Sevastopol
State Duma Deputy (Crimea)
Deputy Speaker of the State Duma
x
91
92
Sidorov
Slutsky
Anatoliy
Leonid
93
Strelkov
Igor
Commander of the Western Military District
Chairman of the State Duma Committee on CIS
Affairs and Eurasian Integration
GRU Officer, Head of separatist forces in Donetsk
94
Surkov
Vladislav
95
Temirgaliev
Rustam
96
97
Tkachev
Totoonov
Alexander
Aleksandr
98
Travkin
Valery
99 Tsekov
100 Turchenyuk
101 Ushakov
Sergey
Lt. Gen. Igor
Yury
102
103
104
105
106
Vladimir
Andrey
Aleksandr
Viktor
Vyacheslav
Vasiliyev
Vasyuta
Vitko
Vodolatsky
Volodin
107 Vorobiev
108 Zheleznyak
109 Zherebtsov
Yuri
Sergei
Yuriy
110 Zhirinovsky
Vladimir
111 Zhurova
Svetlana
112 Zima
Pyotr
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
Aide to the President of the Russian Federation
x
x
x
x
x
x
x
x
x
x
x
Deputy Chairman of the Council of Ministers of
Crimea
Governor, Kransodar Krai
Member of the Federation Council Committee on
Culture, Science and Information
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
Officer, Main Intelligence Directorate, General Staff
of the RF Armed Forces
Vice Speaker of the Crimean parliament
x
Commander of the Russian Forces in Crimea
Aide to the President for Foreign Policy
Deputy Speaker of the RF State Duma
Minister of Industrial Policy of Crimea
Commander of the Black Sea Fleet
Deputy, RF State Duma
First Deputy Chief of Staff of the Presidential
Executive Office
Deputy Speaker of the RF Federation Council
Deputy Speaker of the State Duma
Counsellor of the Speaker of the Crimean
parliament
State Duma Deputy, Founder and Leader of the
Liberal Democratic Party of Russia
First Deputy Chairman, State Duma Committee on
Foreign Affairs
Head of the Crimean Security Service
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
3
x
x
x
x
x
x
SDN List: Private Sector Individuals/Heads of State-Owned Entities
LAST
FIRST
TITLE
1
Bulyutin
Andrey
Kalashnikov Concern
2
Chemezov
Sergei
Director General of Russian Technologies
3
Dedov
Mikhail
Bank Rossiya
4
Dugin
Alexander
Political scientist
5
Kiselyov
Dmitry
Head, Russian State News Agency Rossiya Segodnya
6
7
8
9
10
11
Klishin
Kolbin
Kovalchuk
Kovalchuk
Lebedev
Malofeev
Mikhail
Petr
Kirill
Yuri
Dmitry
Konstantin
12
13
14
15
16
17
Mansurov
Minaev
Omelchenko
Paananen
Prigozhin
Rotenberg
Dmitry
Oleg
Aleksandr
Kai
Yevgeny
Arkady
18
Rotenberg
Boris
19
20
Rotenberg
Sechin
Roman
Igor
21
22
Shamalov
Timchenko
Nikolay
Gennady
Bank Rossiya
Timchenko Associate
Bank Rossiya
Chairman of the Board of Bank Rossiya
Bank Rossiya
Russian businessman accused of financing separatist
groups
Bank Rossiya
Bank Rossiya
Kalashnikov Concern
Timchenko Associate
Entreprenuer (defense sector contracts)
Chairman of SMP Bank and Co-founder of
Stroygazmontazh Corporation
Board Director of SMP Bank and Co-founder of
Stroygazmontazh Corporation
Rotenberg Associate
President and Chairman of the Management Board
of Rosneft
Shareholder, Bank Rossiya
Founder of Volga Group and Co-Founder of Gunvor
23
24
Yakunin
Zaldostanov
Vladimir
Aleksandr
Chairman of Russian Railways
Leader of the Night Wolves biker group
U.S.
x
x
x
EU
Canada
Switzerland
Liechtenstein
x
x
x
x
x
x
x
Australia
Japan
Norway
Albania
Iceland
Montenegro
Ukraine
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
4
SDN List: Entities/Government Agencies
NAME
1
Abros
2
Airfix Aviation Oy
Almaz-Antey**
3
Almaz-Antey GSKB
4
Aquanika
5
6
Avia Group LLC
7
Avia Group Nord LLC
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
Bank Rossiya
Bazalt**
Chernemorneftegaz
Crimean Oil and Gas Co.
Crimean Railway
Crimean Port
Dobrolet
Dolgoprudny Research Production Enterprise
DSK
Evpatoria Port (Crimea)
ExpoBank
Feodosia
Feodosia Optical Plant
Glavgosekpertiza Rossii
Institute Giprostroymost-St. Petersburg
Institute Stroiproekt
Instrument Design Bureau
InvestCapitalBank
IPP Oil Products
Izhevsky Mekhanichesky Zavod
Kalashnikov Concern**
Kalinin Machine Plant
Karst
Kerch Sea Commercial Port
Kerch Sea Ferry
Koksokhimtrans
Kontsern Izhmazh
Langvik Capital Oy
Marshall Capital Fund
37
38
39
40
41
42
43
44
"Marshall Zhukov" (ship)
Mashinostroyenia
Morye Federal Shipyard
Mostotrest
Mytishchinski Mashinostroitelny Zavod
Night Wolves biker group
JSC NIIP
Professional Association of Designers of Data
Processing Systems
45
46
47
48
49
50
Radio-Electronic Technologies
RF Main Intelligence Directorate (GRU)
RF Federal Security Service (FSB)
RosEnergoBank
RusChemTrade
Russkoye Vremya LLC
51
52
53
Russian National Commercial Bank
Set Petrochemicals
Sakhatrans LLC
54
55
56
57
58
Sevastopol Sea Trading Port
SGM Group
SGM-Most
JSC Sirius
SMP Bank
REASON
Owned or controlled by Bank Rossiya
Linked to Timchenko
Sanctioned directly (defense industry)
Sanctioned directly (defense industry)
Owned or controlled by the Volga Group and
Gennady Timchenko
Owned or controlled by the Volga Group and
Gennady Timchenko
Owned or controlled by the Volga Group and
Gennady Timchenko
Sanctioned directly
Sanctioned directly (defense industry)
Sanctioned directly
Sanctioned directly
Operating in Crimea
Operating in Crimea
Sanctioned directly
Sanctioned directly (defense industry)
Kerch Strait bridge
Appropriated by the Crimean Government
Sanctioned directly
Appropriated by the Crimean Government
Operating in Crimea
Kerch Strait bridge
Kerch Strait bridge
Kerch Strait bridge
Sanctioned directly (defense industry)
Controlled by Arkady and Boris Rotenberg
Linked to Timchenko
Linked to Kalashnikov
Sanctioned directly (defense industry)
Sanctioned directly (defense industry)
Kerch Strait bridge
Appropriated by the Crimean Government
Appropriated by the Crimean Government
Operating in Crimea
Linked to Kalashnikov
Linked to Boris Rotenberg
Sanctioned directly (used to finance the separatist
movement)
Sanctions evasion (Sovfracht)
Sanctioned directly (defense industry)
Operating in Crimea
Kerch Strait bridge
Sanctioned directly (defense industry)
Sanctioned directly
Sanctioned directly (defense industry)
Election interference (supports GRU)
U.S.
x
x
x
x
x
Sanctioned directly (defense industry)
Election interference
Election interference
Sanctioned directly
Sanctions evasion (Sovfracht)
Owned or controlled by the Volga Group and/or
Gennady Timchenko
Sanctioned directly (Crimea)
Linked to Timchenko
Owned or controlled by the Volga Group and
Gennady Timchenko
Appropriated by the Crimean Government
Controlled by Arkady Rotenberg
Kerch Strait bridge
Sanctioned directly (defense industry)
Controlled by Arkady and Boris Rotenberg
x
x
x
EU
Canada
x
Switzerland
Liechtenstein
Australia
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
Japan
Norway
Albania
Iceland
Montenegro
Ukraine
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
5
59
60
61
62
63
64
65
66
67
68
69
70
71
SMT-K
Sobinbank JSB
Solid Ltd.
Southeast Trading Oy
Southport Management Services
Sovracht Managing Company
Sovfracht-Sovmortrans Group
Sozvezdie
St. Petersburg Special Technology Center
"Stalingrad" (ship)
STG-Eko
Stroygazmontazh
Stroytransgaz Group
72
Stroytransgaz Holding
73
Stroytransgaz LLC
74
Stroytransgaz OJSC
75
Stroytransgaz-M LLC
76
77
78
Uranis-Radiosystemi
The Volga Group
Transoil
79
80
81
82
83
84
85
86
87
88
89
90
Trans-Flot
Transpetrochart Co. Ltd.
Tula Arms Plant
United Aircraft Corporation
United Shipbuilding Corporation
Uprdor Taman
Uralvagonzavod**
Yalta Sea Trading Port
Zaliv Shipyard
Zest
Zorsecurity, a.k.a. Esage Lab
Zvezdchka Ship Repair Center
Operating in Crimea
Owned or controlled by Bank Rossiya
Sanctions evasion (Sovfracht)
Linked to Timchenko
Linked to Timchenko
Operating in Crimea
Operating in Crimea
Sanctioned directly (defense industry)
Election interference (supports GRU)
Sanctions evasion (Sovfracht)
Kerch Strait bridge
Controlled by Arkady Rotenberg
Owned or controlled by the Volga Group and/or
Gennady Timchenko
Owned or controlled by the Volga Group and/or
Gennady Timchenko
Owned or controlled by the Volga Group and/or
Gennady Timchenko
Owned or controlled by the Volga Group and/or
Gennady Timchenko
Owned or controlled by the Volga Group and/or
Gennady Timchenko
Operating in Crimea
Owned or controlled by Gennady Timchenko
Owned or controlled by the Volga Group and/or
Gennady Timchenko
Sanctions evasion (Sovfracht)
Sanctions evasion (Sovfracht)
Sanctioned directly (defense industry)
Sanctioned directly (defense industry)
Sanctioned directly (defense industry)
Kerch Strait bridge
Sanctioned directly (defense industry)
Appropriated by the Crimean Government
Operating in Crimea
Owned or controlled by Bank Rossiya
Election interference (supports GRU)
Operating in Crimea
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
6
Sectoral Sanctions (U.S. SSI List or EU financial/export prohibitions): Entities
REASON
NAME
Almaz Antey**
1
EU prohibitions on the sale, supply or transfer of
dual-use technologies
2
Sanctioned directly (VTB subsidiary)
Bank of Moscow2
3
Bazalt
4
Chemcomposite
5
Gazprom
6
Gazprombank2
Gazprom Neft
Lukoil
Novatek3
Oboronprom
Rosneft1
7
8
9
10
11
12
2
3
13
14
Russian Agricultural Bank
Sberbank
JSC Sirius
15
Stankoinstrument
16
17
Surgutneftegas
Technologii Maschinostrojenija
18
19
Transneft
Tula Arms Plan
20
21
22
United Aircraft Corporation
Uralvagonzavod**
Vnesheconombank1
VTB
Wysokototschnye Kompleksi
23
24
U.S.
x
EU
x
x
Canada
x
Switzerland
x
Liechtenstein
x
Australia
x
Japan
x
x
Sanctioned directly
x
x
x
Sanctioned directly
Sanctioned directly
Sanctioned directly
x
x
x
x
x
Sanctioned directly
Sanctioned directly
x
x
Iceland
x
Montenegro
x
Ukraine
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
Sanctioned directly
x
x
Sanctioned directly
EU prohibitions on the sale, supply or transfer of
dual-use technologies
EU prohibitions on the sale, supply or transfer of
dual-use technologies
Sanctioned directly
EU prohibitions on the sale, supply or transfer of
dual-use technologies
Sanctioned directly
EU prohibitions on the sale, supply or transfer of
dual-use technologies
Sanctioned directly
Sanctioned directly
Sanctioned directly
x
x
x
Sanctioned directly
EU prohibitions on the sale, supply or transfer of
dual-use technologies
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
Albania
x
x
EU prohibitions on the sale, supply or transfer of
dual-use technologies
EU prohibitions on the sale, supply or transfer of
dual-use technologies
Sanctioned directly
x
Norway
x
x
x
x
x
x
x
x
x
x
x
x
x
x
1: The U.S. on July 30, 2015 specifically added 17 Rosneft and 16 VEB subsidiaries to the SSI list even though "These entities were already subject as a matter of law to the same financing restrictions as their parent entities per OFAC’s 50 percent rule guidance." The move was made to "help the
public more effectively comply with the sanctions on VEB and Rosneft."
2: The U.S. on September 1, 2016 designated 77 Gazprom and Gazprombank subsidiaries and 19 Bank of Moscow subsidiaries that are at least 50 percent owned by those companies "to help the public more effectively comply" with the sanctions regime.
3: The U.S. on December 20, 2016, designated 14 subsidiaries of Russian Agricultural Bank and 12 Novatek subsidiaries that are at least 50 percent owned by those companies "to help the public more effectively comply" with the sanctions regime.
*** Sanctioned for interference in the 2016 U.S. presidential election
** Part of the U.S. asset freeze list, while under financial/dual-use export restrictions from the EU
*Japan announced a temporary visa ban against certain Russian officials, but did not publish that list.
*Switzerland's sanctions list has consistently matched that of the EU, with some delay. However, the sanctions themselves are more limited. In particular, “financial intermediaries based in Switzerland may no longer enter into new business relationships with the [sanctioned EU individuals]. This is intended to ensure that the
named individuals do not transfer assets to Switzerland. Existing business relationships involving the named individuals are not subject to this ban. However, the State Secretariat for Economic Affairs SECO must be notified of such business relationships. By invoking an obligation to notify, the Federal Council aims to gain an
overview of the business relationships that the persons concerned have in Switzerland and of the assets they hold here, so as to be able to decide on further measures if necessary.” In addition there is a de-facto travel ban on sanctioned individuals because of treaty obligations with the EU.
*Norway and Iceland have imposed travel bans and asset freezes on Russian individuals also sanctioned by the EU. Their policy is to broadly follow EU sanctions, but they have been doing so with a delay.
*Liechtenstein’s sanctions list matches the EU’s and includes both individuals and entities. But the measures it has taken are more limited; like Switzerland, Liechtenstein’s sanctions are focused on impeding any new investments or transactions with designated individuals or entities.
7