| The United States has expanded economic sanctions targeting Russia in response to Russia’s purported annexation of the Luhansk, Donetsk, Kherson, and Zaporizhzhya regions of Ukraine following sham referenda in those areas. The sanctioned persons include companies and executives in Russia’s defense sector, non-Russian suppliers of Russia’s defense-industrial base, members of Russia’s financial leadership, family members of top-ranking Russian officials, and members of Russia’s legislature. In conjunction with the new sanctions, the United States Government issued a “clear warning supported by G7 Leaders” that it will target individuals, entities, and countries that provide political or economic support for Russia’s efforts to change the status of Ukrainian territory.
Additional economic sanctions and other measures targeting Russia are likely to be forthcoming in response to ongoing Russian activities in Ukraine. Most notably, both the Commerce and Treasury Departments issued guidance that the United States is preparing to “more aggressively” target third-country individuals and entities providing material support to Russia, in particular to Russia’s military and defense-industrial base and those providing political and economic support for Russia’s attempted annexation and occupation of Ukrainian territory. Companies that continue to do business in Russia will not only need to assess whether these new measures impact that business, but also whether their activities may be supporting Russia’s actions in Ukraine or support companies that are doing so.
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