The case

Yesterday, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned 275 individuals and entities involved in supplying Russia with advanced technology and equipment that it desperately needs to support its war machine.

Source: US Treasury & US Embassy in Switzerland 

The commentary

Yesterday’s action targets both individual actors and sprawling sanctions evasion networks across 17 jurisdictions, including India, the People’s Republic of China (PRC), Switzerland, Thailand, and Türkiye. In addition to disrupting global evasion networks, this action also targets domestic Russian importers and producers of key inputs and other materiel for Russia’s military-industrial base.

The OFAC has added two Swiss lawyers to the sanctions list. They are said to have created companies and trusts to help Russian clients evade sanctions: “Andres Baumgartner (Baumgartner) and Fabio Libero Delco (Delco) are major handlers of Russian assets and are important business and cash flow facilitators for Russians. Baumgartner and Delco have provided trust and corporation formation services to many Russian clients, including sanctioned Russian individuals. Baumgartner and Delco are each the director of many Russian-owned entities”.

The expansion of the US sanctions list is likely to have an impact on the compliance departments of banks and other financial institutions worldwide.

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