On April 15, 2021, President Biden signed a new executive order, Blocking Property with Respect to Specified Harmful Foreign Activities of the Government of the Russian Federation, escalating US sanctions against the Russian government and against Russian actors that threaten US interests. Concurrently, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) made several dozen new sanctions designations—some in coordination with US allies—targeting individuals and entities in connection with Russian interference in the 2020 US presidential election, Russia’s occupation of Crimea, and the cyber-espionage campaign that exploited the SolarWinds platform. OFAC issued a new directive pursuant to the executive order, prohibiting US financial institutions from participating in certain transactions involving Russian sovereign debt and from lending to the Russian government. OFAC also issued several new frequently asked questions (FAQs) providing guidance on its implementation of the new executive order.
