OFAC: Russian Sanctions Target Foreign Banks

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Friday, the President signed a new Russia-related Executive Order advising financial institutions and payments processors that "Foreign financial institutions that conduct or facilitate significant transactions or provide any service involving Russia’s military-industrial base run the risk of being sanctioned by OFAC."

Under these new authorities, OFAC can impose full blocking sanctions on, or prohibit or restrict the maintenance of correspondent accounts in the United States for, foreign financial institutions.

On December 22,  President Biden  signed a new Russia-related Executive Order (E.O.), “Taking Additional Steps With Respect to the Russian Federation’s Harmful Activities.”

The Department of the Treasury's Office of Foreign Assets Control (OFAC) is issuing a Determination Pursuant to Section 11(a)(ii) of E.O. 14024, as amended by the E.O. of December 22, 2023, and a Determination Pursuant to Section 1(a)(i)(B) of E.O. 14068, as amended by the E.O of December 22, 2023. Additionally, OFAC is amending the Determination issued on June 28, 2022, “Prohibitions Related to Imports of Gold of Russian Federation Origin.”

OFAC is also issuing Russia-related General License 83, "Authorizing Certain Transactions Related to the Imports of Certain Categories of Fish, Seafood, and Preparations Thereof Prohibited by Executive Order 14068," General License 84, "Authorizing Transactions Related to Closing a Correspondent or Payable-Through Account," and General License 85, "Authorizing the Wind Down of Transactions and the Closure of Accounts Involving Expobank Joint Stock Company." In addition, OFAC is issuing 12 new, Russia-related Frequently Asked Questions (FAQs 1146-1157) and amending several Russia related Frequently Asked Questions (FAQs 973, 1070, and 1126).

Furthermore, OFAC is publishing a Compliance Advisory to provide guidance to foreign financial institutions on the amendments to E.O. 14024, including practical guidance on how to identify sanctions risks and implement corresponding controls.

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