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On April 15, 2021, following discussions just days earlier of a
potential summit between President Biden and Russian President
Putin and as Russian troops amassed along the Ukrainian border, the
Biden Administration
issued long-awaited and highly anticipated sanctions against
Russia, including a far-reaching new executive order
(
E.O. ), Blocking Property With
Respect To Specified Harmful Foreign Activities Of The Government
Of The Russian Federation, which authorizes sanctions on any person (individual or entity) determined to meet an
expansive array of criteria related to the Russian Federation s