In his speech on Feb. 24, 2022, President Biden announced a second wave of sanctions designed to seriously impact Russia’s financial sector and access to capital. These measures follow an initial sanctions package announced on Feb. 22, 2022, which was targeted at the so-called Donetsk People’s Republic and the Luhansk People’s Republic (collectively, the Covered Regions) as well as the sanctions relating to Nord Stream 2 issued Feb. 23, 2022.