On 12 April 2023, the US and UK competent authorities coordinated to add numerous perceived Russian “financial facilitators” based in Cyprus, Switzerland, Liechtenstein, and other jurisdictions to their asset freeze lists. The focus in this round has been on individuals and firms who have been perceived to have aided sanctioned Russian oligarchs conceal their assets in complex financial networks, typically through shell companies and trust structures.

USA: OFAC designated 25 individuals and 29 entities with touchpoints in 20 jurisdictions. The US Department of State also designated several entities operating in the defence sector of the Russian Federation economy and entities supporting Russia's war against Ukraine, as well as additional entities associated with Russia's State Atomic Energy Corporation (Rosatom). Concurrently, the US Department of Commerce will take action to add 28 entities to its Entity List.

Closer to home, the US has also coordinated with the UK on this matter and has added the principal of a prominent Cyprus law firm (and associated entities) to the Specially Designated Nationals and Blocked Persons (SDN) List on the same day.

UK: Unlike OFAC, the UK Government focussed on two "financial fixers" for Russian oligarchs, the same Cyprus law firm principal referred to above as well as the owner and operator of a prominent Cyprus corporate services provider. The UK designations are automatically implemented in territories subject to UK sanctions jurisdictions, including the UK Overseas Territories of the British Virgin Islands, Cayman Islands, and Bermuda.

The US press release can be found here.

The UK press release can be found here.