The U.S. Department of the Treasury's Office of Foreign Assets Control and the U.S. Department of State issued over 300 new sanctions targeting, among other things, Russia's financial system. Treasury also broadened the definition of “Russia's military-industrial base” to include all persons blocked pursuant to Executive Order 14024 (including designated Russian banks), thereby increasing the secondary sanctions risks for foreign financial institutions that facilitate transactions involving Russia's military industrial base.
In addition, Treasury issued a new Determination Pursuant to Executive Order 14071 (effective September 12, 2024) to restrict Russian military access to software and IT related services including access to enterprise management software, design and manufacturing software, cloud-based services, IT support services, and IT consultancy and design services. This action could affect providers of software and IT related services if the benefit of their services could ultimately be received (whether directly or indirectly) by a person located in the Russian Federation.
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