General Discussion

04/28/21
Biden on Russia: ‘I told them I would respond and we have’
President Biden said Russian President Vladimir Putin “understands” that actions by Moscow against the U.S. will incur consequences, pointing to a host of sanctions imposed on the Russian economy and individuals over election interference and a massive cyber hack of government and private businesses.

“With regard to Russia, I know it concerns some of you, but I made very clear to President Putin that while we don’t seek escalation — but their actions will have consequences if they turn out to be true, and they turned out to be true,” the president said during a speech to a joint session of Congress.

“I responded in a direct and proportionate way to Russia’s interference in our elections and cyberattacks on our government and businesses — and they did both of these things and I told them I would respond and we have.”

Biden in April imposed sanctions on Russia targeting the country’s sovereign debt. He also blacklisted a handful of technology companies, expelled Russian diplomats in the U.S. and sanctioned dozens of individuals over election interference and cyberattacks.

https://thehill.com/policy/international/550864-biden-on-russia-i-told-them-i-would-respond-and-we-have/

Biden administration announces major actions to tackle Russian efforts to influence 2024 election
https://www.cnn.com/2024/09/04/politics/biden-administration-accuse-russia-election-influence-efforts/

Biden administration hits Russia with sanctions over efforts to manipulate U.S. opinion ahead of the election
https://www.nbcnews.com/politics/2024-election/biden-administration-hit-russia-sanctions-trying-manipulate-us-opinion-rcna169541

When we look back at the first two months of the Trump Administration, this is what we see:

No Sanctions Removed: The Trump Administration has not removed or relaxed any of the US sanctions or export controls against Russia.

No New Sanctions on Anniversary of Invasion: For the first time since the invasion in 2022, the United States did not impose new sanctions against Russia around the anniversary of the invasion on February 24.

Biden Energy Sector Sanctions Allowed to Go Into Effect: The Trump Administration allowed the energy sector sanctions imposed at the end of the Biden Administration on January 10 to go into effect. This included a prohibition on US Persons providing petroleum services to anyone in Russia, which had come with a delayed effective date of February 27. The January 10 measures also included a series of wind-down general licenses that expired on February 27 and March 12. See our blog post on these January 10 sanctions here.

Ukraine National Emergency Continued for Another Year: As reported in the Federal Register on February 27, President Trump continued the national emergency with respect to Ukraine for another year, until March 6, 2026. This national emergency was first declared by President Obama in 2014 to address threats to the democracy and sovereignty of Ukraine.

This national emergency underpins a large number of sanctions against individuals and entities in Russia under Executive Order 13662 following Russia’s annexation of Crimea. (Most of the post-2022 sanctions against Russia were based on a different national emergency declared by President Biden in 2021 in Executive Order 14024. However, in its final weeks, the outgoing Biden Administration imposed a number of sanctions under both EO 14024 and EO 13662 in an attempt to make the sanctions more difficult to remove later – see our blog post on the Biden Administration’s final Russia sanctions imposed on January 10 here and January 15 here.)

No New SDNs: The Trump Office of Foreign Assets Control (“OFAC“) has not designated any new parties on its List of Specially Designated Nationals (“SDN List“) under the main Russia sanctions authorities, i.e., EO 14024 and EO 13662. However:

In a coordinated action with the UK and Australia, on February 11, OFAC added a Russian cybercrime operation to the SDN List. While this designation was made under a cybersecurity sanctions program and not the Russia sanctions, this designation of Russian parties was noteworthy given the broader discussions about Russia and cybersecurity happening in the public sphere. See our blog post on this development here.

We also noticed that when OFAC added several members of Ansarallah (the Houthis) to the SDN List on March 5, the press release highlighted that these individuals had negotiated Houthi weapons procurement from Russia. The press release also noted that OFAC was designating a Houthi-affiliated operative and his company that had recruited Yemeni civilians to fight on behalf of Russia in Ukraine. The press release goes into some detail on these allegations, referencing the word Russia more than 20 times and even naming President Putin once.

A Mixed Bag on Enforcement:

Task Force KleptoCapture, one of the Biden era enforcement initiatives, has been disbanded. This was announced in a memo issued by US Attorney General Pam Bondi on February 5. This was a task force within the US Department of Justice focused on enforcing the sanctions against Russian oligarchs. This was the task force behind many of the high-profile asset seizures that were widely reported in the press, such as luxury yachts.

Still, criminal enforcement activity has continued. There has been movement in several cases involving potential violations of export controls prohibited exports of aircraft parts to Russia, including this indictment on February 13 and this sentencing on February 21.

https://sanctionsnews.bakermckenzie.com/us-russia-sanctions-under-trump-current-state-of-play/

October 24, 2025
EU, US and UK Ratchet Up Russia Sanctions

In significant parallel actions this week, the EU and US imposed new sanctions on Russia. While the EU’s 19th sanctions package is much broader in scope, the measures overlap in their focus on the Russian energy sector, with the US imposing full blocking sanctions on Russia’s two largest oil majors, OJSC Rosneft Oil Company (“Rosneft”) and Lukoil OAO (“Lukoil”) and the EU imposing a full ban on Russia-origin liquified natural gas (“LNG”), among other energy sector…
https://sanctionsnews.bakermckenzie.com/eu-us-and-uk-rachet-up-russia-sanctions/

September 3, 2025
New DoD Rule Targets Consulting Services Contractors that Also Work With the Governments of China or Russia, State Sponsors of Terrorism, or Certain Sanctioned Entities

On August 25, 2025, the US Department of Defense (“DoD”) issued a Final Rule amending the Defense Federal Acquisition Regulation Supplement (“DFARS”) to prohibit DoD contracting officers from awarding certain consulting services contracts to contractors where they or their subsidiaries or affiliates hold contracts and subcontracts that involve providing “consulting services” to “covered foreign entities” (“CFEs”) unless they implement a conflict-of-interest mitigation plan. The prohibition applies specifically to contracts assigned a North American Industry Classification…

https://sanctionsnews.bakermckenzie.com/new-dod-rule-targets-consulting-services-contractors-that-also-work-with-the-governments-of-china-or-russia-state-sponsors-of-terrorism-or-certain-sanctioned-entities/

The Trump administration’s downsizing and disbanding of federal agencies has hit efforts that improve election security and monitor foreign influence. That could create gaps for America’s enemies to exploit the next time the country holds a major election
https://apnews.com/article/trump-election-security-fbi-cisa-foreign-interference-98f1e17c8a6d5923db945a27f06458e7

Trump administration retreats in fight against Russian cyber threats
The Trump administration has publicly and privately signaled that it does not believe Russia represents a cyber threat against US national security or critical infrastructure, marking a radical departure from longstanding intelligence assessments.
https://www.theguardian.com/us-news/2025/feb/28/trump-russia-hacking-cyber-security