Introduces secondary sanctions on foreign financial institutions

On 22 December 2023, the President of the United States issued an Executive Order titled "Taking Additional Steps With Respect to the Russian Federation’s Harmful Activities." This order introduces sanctions against foreign financial institutions that assist in evading economic sanctions targeting entities in the technology, defense, construction, aerospace, and manufacturing sectors of the Russian Federation's economy.

These secondary sanctions entail prohibitions on the opening of accounts and the imposition of stringent conditions on the maintenance of such accounts in the United States, as determined by the Secretary of the Treasury. Additionally, the order authorizes the blocking of all property and interests in property located in the United States.

• Type:

  • Treatment and operation (Operational conditions)

• Industry:

  • Services (Financial and insurance activities)

• Sources:

  • The White House, Executive Order on Taking Additional Steps With Respect to the Russian Federation’s Harmful Activities, https://www.whitehouse.gov/briefing-room/presidential-actions/2023/12/22/executive-order-on-taking-additional-steps-with-respect-to-the-russian-federations-harmful-activities/, 22 Dec 2023
  • Akin, New Executive Order Authorizes the Imposition of Secondary Sanctions on Foreign Financial Institutions Facilitating Russia’s Military-Industrial Base and Expands Import Prohibitions on Certain Russian, https://www.akingump.com/en/insights/alerts/new-executive-order-authorizes-the-imposition-of-secondary-sanctions-on-foreign-financial-institutions, 17 Jan 2024