US Targets Russia With New Entity List, Sanctions Package

The U.S. announced a new set of sweeping Russia-related export controls and sanctions this week to mark the two-year anniversary of Moscow’s invasion of Ukraine and to respond to Russian opposition figure Alexei Navalny's death in prison. The measures include nearly 100 additions to the Commerce Department’s Entity List and more than 500 sanctions designations by the Treasury and State departments in what the U.S. said is its largest single tranche of designations since Russia began the war in 2022.

The Entity List additions, effective Feb. 23, target entities in Russia, China, India, Kyrgyzstan, South Korea, Turkey and the United Arab Emirates for supporting Russia’s defense industrial base, including by illegally shipping U.S. goods to Russia. The Bureau of Industry and Security designated more than 50 of the entities as Russian-Belarusian military end users, and the new entities will be subject to a license requirement for all items subject to the Export Administration Regulations. Licenses will be reviewed either under a policy of denial or presumption of denial, with some exceptions for food and medicine.

The new financial sanctions target Russian government officials responsible for Navalny’s death; more than two dozen sanctions evaders in Europe, East Asia, Central Asia and the Middle East; hundreds of companies with ties to Russia’s military-industrial base; parties helping Russia earn revenue from energy sales, and more. The Office of Foreign Assets Control also issued several new general licenses and released new sanctions guidance.

Along with the new restrictions, the U.S., the EU, the U.K. and Japan expanded its list of common high-priority items Russia is seeking to import to now include several new goods, including certain “computer numerically controlled” machine tools. The U.S. also issued a new business advisory to warn companies about Russia-related compliance risks.