Yesterday, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated several Russian individuals and entities as Specially Designated Nationals (SDNs) pursuant to the Countering America’s Adversaries Through Sanctions Act of 2017 (CAATSA) and a cyber-related Executive Order. The new sanctions are retaliation for Russia’s interference in the most recent presidential election as well as cyberattacks linked to Russia, including the NotPetya cyberattack and other intrusions targeting U.S. government entities and critical U.S. infrastructure.
Many of the newly designated persons also have been charged by Special Counsel Robert Mueller for crimes related to the 2016 presidential election. One such entity—the Internet Research Agency—allegedly was founded for the specific purpose of meddling in the U.S. election. This entity allegedly created fictitious online users posing as Americans and infiltrated social media sites. Other designees, including Russia’s Federal Security Service and its Main Intelligence Directorate, were already subject to U.S. sanctions broadly prohibiting most dealings with these entities.
This marks the first major action the Trump administration has taken against Russia to address election interference. And, there may be more to come. Earlier this year, the administration submitted a report to Congress, as required under CAATSA, identifying Russian oligarchs, senior political figures, and parastatal entities. The report itself is not a sanctions list, although it potentially could serve as a starting point for additional Russian designations.