Sunday after the invasion
Stakes · Whether the United States leads a G7 package that freezes Bank of Russia reserves or moves alone on OFAC names.
Russia invaded Ukraine on 24 February 2022. You are drafting the next tranche of Office of Foreign Assets Control () designations under the International Emergency Economic Powers Act ().
Allies are on the phone about Bank of Russia reserves — hundreds of billions in Group of Seven () jurisdictions.
You can table a full G7 package: expand OFAC lists, freeze reserves where custodians agree, and remove selected Russian banks from SWIFT once Brussels is ready. You can move U.S.-only on banks and oligarchs. You can lead with SWIFT and defer the reserve freeze.
Constraints of the office here
- — Reserves sit in Frankfurt, Paris, Tokyo, and New York custodians.
- — SWIFT requires EU and Belgian action.
- — Congress will ask why energy payments still flow.
Options · keys 1–3