Administration's Rico Proposals Could Provide Significant New Enforcement Tools Against Russian Oligarchs

Washington, D.C. (May 20, 2022) -  In March 2022, in response to Russia's actions in the Ukraine conflict, the U.S. Treasury Department's Office of Foreign Assets Control (OFAC) issued sanctions targeting Russian "elites and business executives who are associates and facilitators of the Russian regime" (see Lewis Brisbois' April 13 alert). The result of these sanctions was to place the names of these individuals – often referred to as " oligarchs" – on the Specially Designated Nationals and Blocked Persons list (SDN List). That action prohibits U.S. persons from engaging in any transfer of products or payments to, or financing of any property interest of anyone on the SDN List, and the ban extends to any entity that is directly or indirectly 50% or more owned by any SDN-listed party, whether or not the entity itself is listed.