In July, the U.S. Treasury Department imposed a broad-based package of economic sanctions on entities in the financial services, energy, and arms or related sectors of Russia, and on those undermining Ukraine’s sovereignty or misappropriating Ukrainian property.
Treasury’s Office of Foreign Assets Control (OFAC) introduced the Sectoral Sanctions Identifications (SSI) List to identify these sanction targets. The SSI List is not part of OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List), although some SSI targets may also appear on the SDN List.
Generally, U.S. persons are prohibited from providing debt financing longer than 90 days or new equity to any person/entity on the SSI List. But targets’ assets under U.S. jurisdiction aren’t “blocked” (i.e., frozen) under this particular sanction program. OFAC posted detailed information on how to handle SSIs on its website.
Earlier this year, OFAC issued another non-SDN List—the Foreign Sanctions Evaders (FSE) List— targeting individuals and entities involved in violating U.S. sanctions on Syria or Iran. Transactions by U.S. persons or within the United States involving FSEs are prohibited (CU Mag 4/14, p. 39). Make sure your OFAC software vendors are tracking the SSI and FSE Lists in addition to the SDN List.