US Releases New Russia Sanctions EO, Guidance

President Joe Biden on Dec. 22 signed an executive order that expands U.S. sanctions authorities against foreign financial institutions facilitating “significant transitions” involving Russia’s military industrial base. The order authorizes new sanctions against banks facilitating those transactions on behalf of certain already-designated parties and it allows the U.S. to sanction banks facilitating sales of certain “critical items” to Russia, the White House said in a fact sheet.

The Treasury Department issued a list of those critical items along with several new general licenses, a new compliance advisory to provide guidance on the order and new frequently asked questions.

Financial institutions sanctioned under this authority will face full blocking sanctions or will either lose or face “strict conditions” on their U.S. correspondent bank accounts, the White House said. A senior administration official said Dec. 21 that the order marks the first time the U.S. is introducing a tool allowing it to impose secondary sanctions against banks indirectly aiding Russia's military.