Mechanism
Executive Order 14024 (15 April 2021, "Blocking Property With Respect To Specified Harmful Foreign Activities of the Government of the Russian Federation") established the legal authority for a comprehensive, sector-spanning sanctions architecture targeting Russia. The order declared a national emergency and authorised OFAC to designate individuals and entities operating in specified Russian economic sectors, to impose sectoral prohibitions, and to issue blocking orders.
31 CFR Part 587 — Interim Final Rule (1 March 2022)
One week after Russia's full-scale invasion of Ukraine on 24 February 2022, OFAC formalised the regulatory framework by publishing the RuHSR as an abbreviated interim final rule. This action does not itself impose new substantive prohibitions; rather, it provides the codified regulatory home for all EO 14024 measures, including:
- The Financial Services Sectoral Determination (22 February 2022), which subjects all persons operating in Russia's financial sector to potential designation.
- Directive 1A (sovereign debt prohibition), Directive 2 (correspondent account prohibitions for designated Russian banks), Directive 3 (new debt/equity prohibitions for Russian entities in key sectors), and Directive 4 (full blocking of the Central Bank of the Russian Federation, National Wealth Fund, and Ministry of Finance).
By placing these measures within an established CFR part, OFAC created a durable legal structure capable of absorbing successive amendments — sectoral determinations, general licenses, new designations, and supplementary guidance — without requiring new standalone rulemaking for each subsequent action.
Interim vs. Final Rule
OFAC indicated it was issuing the rule in abbreviated form "for the purpose of providing immediate guidance to the public," consistent with its practice in prior sanctions programs (e.g., the Iranian Transactions and Sanctions Regulations, Cuban Assets Control Regulations). The abbreviated interim rule omits the full preamble and regulatory analysis typical of final rules; these were expected to follow in a more comprehensive revision.
Downstream implications
- Established Part 587 as the regulatory anchor for all subsequent OFAC Russia-sanctions actions under EO 14024, including hundreds of SDN designations, new sectoral determinations (energy, metals/mining, defence), and dozens of general licenses issued through 2025–26.
- Compliance programmes at US financial institutions, law firms, and multinational exporters required immediate re-mapping of internal Russia-sanctions controls to 31 CFR 587.
- The CFR codification enables private causes of action and OFAC civil penalty proceedings to cite a stable regulatory section rather than referencing an executive order directly.
- Subsequent supplementary rulemakings (the most comprehensive set of RuHSR regulations was published in full form later in 2022) added extensive general-license architecture (GLs 1–130+) that calibrated humanitarian carve-outs, wind-down provisions, and sector-specific exemptions.
Open questions
- OFAC noted intent to issue a comprehensive final rule supplementing Part 587; as of 2026 the program remains primarily administered through web-published general licenses rather than a fully-codified regulation, which raises questions about regulatory transparency for non-US entities subject to secondary-sanctions risk.