Following the recent Ukraine-related designations, media reports can’t seem to decide whether the United States is escalating pressure on Russia or standing firm. U.S. Tightens Russia Sanctions After Putin Blocks MH17 Court claims Bloomberg, while the Wall Street Journal’s piece reads U.S. Names New Sanctions Targets in ‘Maintenance’ Move.’ So who is right? Did the U.S. just expand its sanctions pressure or Russia or is it merely maintaining a regime that had displayed weak links.

I’m inclined to (mostly) side with the WSJ, which reflects the views of the Treasury Department and the Office of Foreign Assets Control (“OFAC”). The entities added to the Sectoral Sanctions Identification (“SSI”) List additions were, as noted by Treasury, already sanctioned by function of law as a result of being 50 percent owned or controlled by already-listed entities. U.S. companies with adequate due diligence procedures should already have been aware of the financing restrictions on these newly listed entities. Similarly, because U.S. entities are already broadly prohibited from dealing with Crimea, the designation of a number of Crimean port operators does not alter compliance responsibilities significantly.

The only part of the action that slightly signals escalation is the designations of Oleksandr Yanukovych, Kai Paananen, and Roman Rotenberg. Oleksandr Yanukovych, the son of former Ukrainian President Viktor Yanukovych controls a significant business empire. Paananen and Rotenberg (the son of designated Russian oligarch Boris Rotenberg) are also large business-owners, not to mention Finnish citizens. Finaland has apparently demanded the U.S. provide an explanation as to the reasons behind these designations. While there’s no reason to doubt Treasury’s justification of the designations, that these individuals were assisting in sanctions evasion, their inclusion on the list of Specially Designated Nationals and Blocked Persons will have an impact beyond reinforcing existing designations.