The OFAC Russia sanctions are a layered set of U.S. economic and financial measures administered by the Treasury Department's Office of Foreign Assets Control. They restrict transactions with designated Russian individuals, companies, banks, and economic sectors, and they implement executive orders issued by the President alongside statutes passed by Congress.
The program developed in several waves:
- 2014 (Crimea and eastern Ukraine): Following Russia's annexation of Crimea, President Obama issued Executive Orders 13660, 13661, 13662, and 13685. These created the first modern Russia/Ukraine sanctions architecture, including the Sectoral Sanctions Identifications (SSI) List under Directives 1–4, which restrict dealings in new debt and equity of major Russian financial, energy, and defense firms.
- 2017: Congress codified and expanded sanctions through the Countering America's Adversaries Through Sanctions Act (CAATSA), limiting presidential discretion to lift measures.
- 2021: Executive Order 14024 created a broad authority to designate persons operating in specified sectors of the Russian economy or acting on behalf of the Russian government.
- 2022–present (full-scale invasion of Ukraine): OFAC and allied jurisdictions sharply escalated designations, blocking major banks such as Sberbank and VTB, imposing correspondent banking restrictions, prohibiting new investment in Russia, and implementing the G7 price cap on Russian seaborne crude and petroleum products.
Designated parties appear on the Specially Designated Nationals (SDN) List; their U.S.-jurisdiction property is blocked, and U.S. persons are generally prohibited from transacting with them. OFAC issues General Licenses authorizing specific categories of activity (humanitarian transactions, wind-downs, energy payments during defined windows) and Specific Licenses on application.
Secondary sanctions risk under EO 14024 (as amended by EO 14114 in December 2023) extends exposure to non-U.S. financial institutions that facilitate significant transactions for Russia's military-industrial base. Compliance therefore requires screening against the SDN List, sector-based directives, and item-level export controls coordinated with the Commerce Department's BIS.
Example
In February 2024, OFAC designated more than 500 targets on the second anniversary of Russia's full-scale invasion of Ukraine, including the operator of Russia's Mir payment system, the National Payment Card System (NSPK).
Frequently asked questions
No. Some major banks such as Sberbank and VTB are on the SDN List with full blocking sanctions, while others face narrower correspondent banking restrictions or sectoral limits. Status varies and should be checked against current OFAC listings.
Keep learning