Entities Engaged in Activities in Russia and Belarus

Agency:	State Government of New Jersey
State:	New Jersey
Type of Government:	State & Local
NAICS Category:	541990 - All Other Professional, Scientific, and Technical Services
Posted Date:	Jun 25, 2026
Due Date:
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Description

Date	Title
1.24.2024	Entities Engaged in Activities in Russia and Belarus

NOTICE REGARDING N.J.S.A. 52:32-60.1

Entities Engaged in Prohibited Activities in Russia and Belarus

Updated January 22, 2024

N.J.S.A. 52:32-60.1 requires the Department of the Treasury (Treasury) to establish a list of persons and

entities engaging in prohibited activities in Russia or Belarus. The law prohibits the State from (1) entering

into or renewing contracts; (2) approving or renewing Public Works Contractor Registrations; (3)

approving economic development subsidies; (4) providing tax clearance certificates; and (5) certifying

urban renewal entities for the purposes of the “Long Term Tax Exemption Law” with a person or entity

identified on the list.

On December 22, 2023, a company obtained a permanent injunction from the United States District Court

for the District of New Jersey, which enjoins the State from enforcing N.J.S.A. 52:32-60.1 against that

company on the ground that such enforcement would conflict with the existing federal sanctions regime

and thus violate the U.S. Constitution’s Supremacy Clause.

N.J.S.A. 52:32-60.4 provides that N.J.S.A. 52:32-60.1 “shall not apply in circumstances when their

application would violate federal law.” Accordingly, to enforce N.J.S.A. 52:32-60.1 in a manner consistent

with the District Court’s decision and federal law, Treasury deems its list of persons and entities engaging

in prohibited activities in Russia or Belarus to consist of all persons and entities appearing on the list of

Specially Designated Nationals and Blocked Persons promulgated by the Office of Foreign Assets Control

(OFAC) on account of activity relating to Russia or Belarus. A searchable database of OFAC-listed persons

and entities is available here: https://sanctionssearch.ofac.treas.gov/.

State agencies shall ensure that they review the OFAC Specially Designated Nationals and Blocked Persons

list prior to (1) entering into or renewing contracts; (2) approving or renewing Public Works Contractor

Registrations; (3) approving economic development subsidies; (4) providing tax clearance certificates; and

(5) certifying urban renewal entities for the purposes of the “Long Term Tax Exemption Law” with any

vendor.

Treasury is publishing a revised Certification of Non-Involvement In Prohibited Activities in Russia or

Belarus form in light of the District Court’s decision. Vendors are required to complete and submit the

revised Certification of Non-Involvement In Prohibited Activities in Russia or Belarus to the State agency

when (1) entering into or renewing contracts; (2) seeking a Public Works Contractor Registration; (3)

seeking an economic development subsidy; (4) seeking a tax clearance certificate; or (5) seeking a “Long

Term Tax Exemption Law” as an urban renewal entities.

This page summarizes the opportunity, including an overview and a preview of the attached documents.

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