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 misappropriation of its assets, and thereby constitute an unusual and extraordinary threat to the national security and foreign policy of the United States."

EO 13661 authorized sanctions against several specifically listed Russian government officials and instructed OFAC to identify additional individuals who "have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of a senior official of the Government of the Russian Federation." Pursuant to the order, on March 20, 2014, OFAC designated 16 Russian government officials and 4 members of President Putin's inner circle, including Arkady and Boris Rotenberg. President Obama later issued additional executive orders on March 20, 2014 and December 19, 2014, expanding the scope of the sanctions.

In addition to executive branch actions, Congress passed two laws sanctioning Russian individuals and entities in 2014: (1) Support for the Sovereignty, Integrity, Democracy, and Economic Stability of Ukraine Act and (2) Ukraine Freedom Support Act. These laws permitted sanctions against any person "the President determines has perpetrated, or is responsible for ordering, controlling, or otherwise directing, significant acts of violence or gross human rights abuses in Ukraine." They also included "potentially wide-reaching secondary sanctions against foreign individuals and entities that facilitate significant transactions for Russia sanctions designees, help them to evade sanctions, or make significant investments in certain oil projects in Russia."

Like the United States, the European Union also issued economic sanctions against Russia for its invasion of Ukraine. These restrictions included bans on "goods originating in Crimea unless they have Ukrainian certificates," and export prohibitions on "[g]oods and technology for the transport,