On Apr 6, 2018, the US Department of the Treasury'south Office of Strange Assets Command (OFAC) added vii Russian individuals and twelve companies deemed to exist endemic or controlled by those individuals to the List of Specially Designated Nationals and Blocked Persons (SDN Listing). OFAC also added seventeen senior Russian government officials, a Russian trading visitor, and a Russian bank to the SDN Listing. In connection with these designations, OFAC issued General License 12, authorizing sure activities that are ordinarily incident and necessary to the maintenance or wind-down of operations, contracts, or other agreements involving certain blocked persons, and General License 13, authorizing sure activities that are ordinarily incident and necessary to divest or transfer debt, equity, or other holdings in certain blocked persons.

These actions are pursuant to authority provided under Executive Order (EO) 13661 and EO 13662, authorities codified by the Countering America's Adversaries Through Sanctions Act (CAATSA), as well as EO 13582.1 They follow the Department of the Treasury's issuance on Jan 29, 2022 of its study to Congress identifying "Russian Senior Foreign Political Figures and Oligarchs in the Russian federation and Russian Parastatal Entities," as required by Section 241 of CAATSA. The new designations announced past OFAC on Apr half-dozen, 2018, which are summarized below, target several of the individuals listed in the written report.

New Additions to the Specially Designated Nationals List

The United States announced 38 additional designations to the SDN List.

Seven Russian individuals were designated because they were determined by the Secretarial assistant of the Treasury to operate in the free energy sector of the Russian economy, to accept acted or purported to human activity for or on behalf of, direct or indirectly, a senior official of the Government of the Russian Federation, and/or to be an official of the Authorities of the Russian Federation. The Treasury Department provided the following data about these designations:

  • Vladimir Bogdanov, the Director Full general and Vice Chairman of the Board of Directors of Surgutneftegaz, is being designated for operating in the free energy sector of the Russia economic system;
  • Oleg Deripaska is being designated pursuant to EO 13661 for having acted or purported to act for or on behalf of, directly or indirectly, a senior official of the Government of the Russian federation, and pursuant to EO 13662 for operating in the free energy sector of the Russia economic system;
  • Suleiman Kerimov, a member of the Russian Federation Council, is being designated for being an official of the Government of the Russian Federation;
  • Igor Rotenberg "acquired significant avails from his father, Arkady Rotenberg, after OFAC designated the latter in March 2014," and is beingness designated for operating in the energy sector of the Russia economic system;
  • Kirill Shamalov, Vladimir Putin'due south son-in-law, "acquired a big portion of shares of Sibur, a Russia-based company involved in oil and gas exploration, production, processing, and refining," and is being designated for operating in the energy sector of the Russian Federation economy;
  • Andrei Skoch, a deputy of the Russian federation's State Duma "has longstanding ties to Russian organized criminal groups, including fourth dimension spent leading ane such enterprise," and is being designated for existence an official of the Government of the Russia;
  • Viktor Vekselberg, the founder and Chairman of the Board of Directors of the Renova Group, is being designated for operating in the free energy sector of the Russia economy;

Twelve companies also were adamant by the Secretary of Treasury to be owned or controlled, direct or indirectly, by certain of the above individuals.

In addition, one Russian trading visitor, Rosoboroneksport, was adamant by the Secretary of the Treasury to accept materially assisted, sponsored, or provided financial, material, or technological back up for, or goods or services in back up of, the Government of Syria. The Russian Financial Corporation Bank (RFC Banking company) was determined past the Secretary of the Treasury to be endemic by Rosoboroneksport.

Seventeen additional Russian individuals were determined by the Secretary of the Treasury to exist officials of the Government of the Russian Federation. The Treasury Department determined that each of these individuals is affiliated with a Russian state-owned enterprise, such every bit Gazprom or its subsidiaries, or with a Russian government entity such as the Russian federation Security Council, the Russian State Duma, the Primal Bank of the Russian federation, the Ministry of Interior, the President of the Russia, the Federal Service of National Baby-sit Troops, the Russian Establish for Strategic Studies, the Presidential Directorate for Social and Economic Cooperation with the Commonwealth of Contained States Member Countries, the Ministry of Internal Affairs, the Council of the Federation Committee on Strange Affairs, or the Federal Service for the Supervision of Communications, Information Technology, and Mass Media.

Unless authorized, all holding and interests in holding of the designated individuals and entities located in the United States or within the possession or control of a United states of america persontwo , wherever located, are considered blocked and may non be dealt in. Whatsoever entity in which a blocked person holds a l percent or greater ownership interest is itself considered blocked by operation of law. US persons may not engage in whatever dealings, directly or indirectly, with blocked persons. Provision of goods, services or support for blocked parties is identified as a criterion for potential future designation.

OFAC has provided the post-obit listing of individuals and entities designated on the SDN List:

Individuals:

  • AKIMOV, Andrey Igorevich, Russia; DOB 1953; POB Leningrad, Russia; Gender Male; Chairman of the Management Board of Gazprombank (individual) [UKRAINE-EO13661].
  • BOGDANOV, Vladimir Leonidovich, Russia; DOB 28 May 1951; POB Suyerka, Uporovsky District, Tyumen Region, Russian Federation; Gender Male person (individual) [UKRAINE-EO13662].
  • DERIPASKA, Oleg Vladimirovich, Moscow, Russian federation; 64 Severnaya Street, Oktyabrsky, Khutor, UstLabinsky District, Krasnodar Territory 352332, Russia; 5, Belgrave Square, Belgravia, London SW1X 8PH, United Kingdom; DOB 02 January 1968; POB Dzerzhinsk, Nizhny Novgorod Region, Russia; citizen Russian federation; alt. citizen Cyprus; Gender Male (individual) [UKRAINE-EO13661] [UKRAINE-EO13662].
  • DYUMIN, Alexey Gennadyevich (a.k.a. DYUMIN, Alexei), Russia; DOB 28 Aug 1972; POB Kursk, Russian Federation; Gender Male (individual) [UKRAINE-EO13661].
  • FRADKOV, Mikhail Efimovich (Cyrillic: ФРАДКОВ, Михаил Ефимович), Russia; DOB 01 Sep 1950; POB Kurumoch, Kuibyshev Region, Russian federation; Gender Male; Director of the Russian Constitute for Strategic Studies (individual) [UKRAINE-EO13661].
  • FURSENKO, Sergei (a.k.a. FURSENKO, Sergey; a.chiliad.a. FURSENKO, Sergey Aleksandrovich); DOB 11 Mar 1954; POB Saint-Petersburg (F.K.A. Petrograd), Russia; denizen Russia; Gender Male (individual) [UKRAINE-EO13661].
  • GOVORUN, Oleg, Russian federation; DOB 15 Jan 1969; POB Bratsk, Irkutsk Region, Russia; Gender Male person; Head of the Presidential Directorate for Social and Economic Cooperation with the Democracy of Contained States Fellow member Countries, the Republic of Abkhazia, and the Republic of Southward Ossetia (private) [UKRAINE-EO13661].
  • KERIMOV, Suleiman Abusaidovich (Cyrillic: КЕРИМОВ, Сулейман Абусаидович) (a.g.a. KERIMOV, Suleyman), Moscow, Russia; Antibes, French republic; DOB 12 Mar 1966; POB Derbent, Republic of Dagestan, Russian federation; citizen Russia; Gender Male (individual) [UKRAINE-EO13661].
  • KOLOKOLTSEV, Vladimir Alexandrovich, Russia; DOB 11 May 1961; POB Nizhny Lomov, Penza Region, Russia; Gender Male; Minister of Internal Affairs of the Russia, Full general of the Law of the Russian Federation (individual) [UKRAINE-EO13661].
  • KOSACHEV, Konstantin, Russia; DOB 17 Sep 1962; POB Moscow, Russia; nationality Russian federation; Gender Male; Chairperson of the Council of the Federation Committee on Strange Affairs (individual) [UKRAINEEO13661].
  • KOSTIN, Andrey Leonidovich, Moscow, Russia; DOB 21 Sep 1956; POB Moscow, Russia; Gender Male (individual) [UKRAINE-EO13661].
  • MILLER, Alexey Borisovich, Moscow, Russia; DOB 31 Jan 1962; POB Saint-Petersburg, Russia; Gender Male (private) [UKRAINE-EO13661].
  • PATRUSHEV, Nikolai Platonovich, Russia; DOB 11 Jul 1951; POB Leningrad, Russian federation; nationality Russia; Gender Male; Secretary of the Russia Security Quango (individual) [UKRAINE-EO13661].
  • REZNIK, Vladislav Matusovich, Moscow, Russian federation; DOB 17 May 1954; Gender Male (individual) [UKRAINEEO13661].
  • ROTENBERG, Igor Arkadyevich (a.chiliad.a. ROTENBERG, Igor Arkadevich); DOB 09 May 1973; POB Leningrad, Russia; Gender Male (individual) [UKRAINE-EO13662].
  • SHAMALOV, Kirill Nikolaevich; DOB 22 Mar 1982; POB Leningrad, Russia; Gender Male (individual) [UKRAINE-EO13662].
  • SHKOLOV, Evgeniy Mikhailovich, Russia; DOB 31 Aug 1955; POB Dresden, Frg; nationality Russia; Gender Male; Aide to the President of the Russian Federation (individual) [UKRAINE-EO13661].
  • SKOCH, Andrei Vladimirovich (a.thou.a. SKOCH, Andrey), Russia; DOB xxx Jan 1966; POB Nikolsky (Moscow), Russia; Gender Male; Deputy of Country Duma (private) [UKRAINE-EO13661].
  • TORSHIN, Alexander Porfiryevich, Moscow, Russia; DOB 27 Nov 1953; POB Mitoga village, UstBolsheretsky commune, Kamchatka region, Russia; Gender Male person (individual) [UKRAINEEO13661].
  • USTINOV, Vladimir Vasilyevich, Russia; DOB 25 Feb 1953; POB Nikolayevsk-on-Amur, Russian federation; Gender Male (individual) [UKRAINE-EO13661].
  • VALIULIN, Timur Samirovich, Russia; DOB 20 Dec 1962; POB Krasnozavodsk, Zagorsk Commune, Moscow Region, Russian federation; Gender Male person; Master of the Full general Assistants for Combating Extremism of the Ministry building of Internal Affairs of the Russian Federation (private) [UKRAINE-EO13661].
  • VEKSELBERG, Viktor Feliksovich, Russia; DOB 14 Apr 1957; POB Drogobych, Lviv region, Ukraine; Gender Male (individual) [UKRAINE-EO13662].
  • ZHAROV, Alexander Alexandrovich (a.m.a. ZHAROV, Aleksandr), Russia; DOB 11 Aug 1964; POB Chelyabinsk, Russia; Gender Male person; Caput of the Federal Service for Supervision of Communications, Data Technology, and Mass Media (individual) [UKRAINE-EO13661].
  • ZOLOTOV, Viktor Vasiliyevich, Russia; DOB 27 Jan 1954; POB Ryazanskaya oblast, Russian federation; nationality Russian federation; Gender Male person; Director of the Federal Service of National Guard Troops and Commander of the National Guard Troops of the Russian federation (individual) [UKRAINE-EO13661]

Entities

  • AGROHOLDING KUBAN (a.k.a. KUBAN AGRO; a.k.a. KUBAN AGROHOLDING), 77 Mira St., UstLabinsk, Krasnodar Territory 352330, Russian federation; 1 Montazhnaya St., Ust-Labinsk, Krasnodar Territory, Russia; 116 Mira St., Ust-Labinsk, Krasnodar Territory, Russia; 1 Thousand. Konshinykh St., Krasnodar Territory, Russia; 2 Rabochaya St., Ust-Labinsk, Krasnodar Territory, Russia [UKRAINE-EO13661] [UKRAINEEO13662] (Linked To: DERIPASKA, Oleg Vladimirovich; Linked To: Basic Chemical element Express).
  • BASIC Chemical element Limited (a.k.a. BAZOVY ELEMENT), Esplanade 44, Saint Helier JE4 9WG, Bailiwick of jersey; thirty Rochdelskaya Street, Moscow 123022, Russian federation; Registration ID 84039 [UKRAINE-EO13661] [UKRAINE-EO13662] (Linked To: DERIPASKA, Oleg Vladimirovich).
  • B-FINANCE LTD, Vanterpool Plaza, 2d Floor, Wickhams Cay, Road Town, Tortola, Virgin Islands, British [UKRAINE-EO13661] [UKRAINE-EO13662] (Linked To: DERIPASKA, Oleg Vladimirovich).
  • EN+ GROUP PLC, Esplanade 44, Saint Helier JE4 9WG, Jersey; viii Cleveland Row, London SW1A 1DH, United Kingdom; 1 Vasilisy Kozhinoy St., Moscow 121096, Russia; Registration ID 91061 [UKRAINEEO13661] [UKRAINE-EO13662] (Linked To: DERIPASKA, Oleg Vladimirovich).
  • GAZ Group, 88 Lenin Avenue, Nizhny Novgorod 603950, Russia; 15/1 Rochdelskaya Str., Moscow 123022, Russian federation [UKRAINE-EO13661] [UKRAINE-EO13662] (Linked To: DERIPASKA, Oleg Vladimirovich; Linked To: RUSSIAN MACHINES).
  • GAZPROM BURENIE, OOO (f.grand.a. BUROVAYA KOMPANIYA OAO GAZPROM, DOCHERNEE OBSHCHESTVO South OGRANICHENNOI OTVETSTVENNOSTYU; a.grand.a. GAZPROM BURENIYE LLC; a.k.a. GAZPROM DRILLING; a.yard.a. Express LIABILITY Visitor GAZPROM BURENIYE; a.chiliad.a. OBSHCHESTVO S OGRANICHENNOI OTVETSTVENNOSTYU GAZPROM BURENIE), 12A, ul. Nametkina, Moscow 117420, Russia; Website www.burgaz.ru; E-mail Accost [email protected]; Registration ID 1028900620319; Tax ID No. 5003026493; Regime Gazette Number 00156251 [UKRAINE-EO13662] (Linked To: ROTENBERG, Igor Arkadyevich).
  • JSC EUROSIBENERGO, 165 Chkalova Street, Divnogorsk, Krasnoyarsk Krai 663091, Russian federation; 1 Vasilisy Kozhinoy Street, Moscow 121096, Russia; Registration ID 5087746073817; Tax ID No. 7706697347; Identification Number 88303955 [UKRAINE-EO13661] [UKRAINE-EO13662] (Linked To: DERIPASKA, Oleg Vladimirovich; Linked To: EN+ GROUP PLC).
  • LADOGA MENEDZHMENT, OOO (a.1000.a. OBSHCHESTVO Southward OGRANICHENNOI OTVETSTVENNOSTYU LADOGA MENEDZHMENT; a.g.a. OOO LADOGA Management), 10, naberezhnaya Presnenskaya, Moscow 123317, Russia; Registration ID 1147748143971; Tax ID No. 7729442761; Government Gazette Number 29437172 [UKRAINE-EO13662] (Linked To: SHAMALOV, Kirill Nikolaevich).
  • NPV ENGINEERING Open up JOINT STOCK Company (a.chiliad.a. AKTSIONERNOE OBSHCHESTVO ENPIVI INZHINIRING; a.k.a. AO ENPIVI INZHINIRING; a.k.a. ENPIVI INZHINIRING, AO; a.k.a. NPV ENGINEERING JOINT STOCK Visitor; a.k.a. OJSC NPV Engineering science), five, per. Strochenovski B., Moscow 115054, Russian federation; PER. Strochenovskii B D.five, Moscow 115054, Russia; Website www.npve.narod.ru; Email Address [email protected]; Registration ID 106774653683; Tax ID No. 7707587805; Government Gazette Number 95533058 [UKRAINE-EO13662] (Linked To: ROTENBERG, Igor Arkadyevich)
  • RENOVA GROUP (a.yard.a. Articulation-STOCK Visitor RENOVA GROUP OF COMPANIES; a.m.a. JSC RENOVA Group OF COMPANIES), V, 28 Balaklavskiy Prospekt, Moscow 117452, Russia; 40, Malaya Ordynka, Moscow 115184, Russian federation; Registration ID 1047796880548; Tax ID No. 7727526670; Government Gazette Number 772701001 [UKRAINE-EO13662] (Linked To: VEKSELBERG, Viktor Feliksovich).
  • ROSOBORONEKSPORT OAO (a.k.a. OJSC ROSOBORONEXPORT; a.k.a. ROSOBORONEKSPORT OJSC; a.k.a. ROSOBORONEXPORT; a.thousand.a. ROSOBORONEXPORT JSC; a.k.a. RUSSIAN Defence Export ROSOBORONEXPORT), 27 Stromynka ul., Moscow 107076, Russia; Website www.roe.ru; Executive Club 13662 Directive Determination - Subject to Directive 3; Registration ID 1117746521452; Taxation ID No. 7718852163; Government Gazette Number 56467052; For more than information on directives, delight visit the following link: http://world wide web.treasury.gov/resourcecenter/sanctions/Programs/Pages/ukraine.aspx#directives [SYRIA] [UKRAINE-EO13662] (Linked To: ROSTEC).
  • RUSSIAN FINANCIAL CORPORATION (a.k.a. AO RFK-BANK; a.k.a. Bank ROSSISKAYA FINANSOVAYA KORPORATSIYA AKTSIONERNOE OBSHCHESTVO; a.m.a. RFC-BANK; a.thousand.a. RUSSIAN FINANCIAL CORPORATION BANK JSC), St. George's Lane, D. i, p. 1, Moscow 125009, Russia; d. 1 korp, 1 per. Georgievski, Moscow 125009, Russia; SWIFT/BIC RFCBRUMM; alt. SWIFT/BIC 044525257 [Syrian arab republic].
  • RUSSIAN MACHINES (a.thousand.a. RUSSKIE MASHINY), Ul. Rochdelskaya 15, eight, Moscow 123022, Russia; Registration ID 1112373000596; Taxation ID No. 2373000582; Identification Number 37100386 [UKRAINEEO13661] [UKRAINE-EO13662] (Linked To: DERIPASKA, Oleg Vladimirovich; Linked To: Bones ELEMENT LIMITED).
  • UNITED COMPANY RUSAL PLC, 44 Esplanade, St. Helier JE4 9WG, Bailiwick of jersey; i Vasilisy Kozhinoy Str., Moscow 121096, Russia; eleven/F Fundamental Twr., 28 Queen's Rd. C, Central District, Hong Kong; Registration ID 94939; Company Number F-17314 (Hong Kong); Business concern Number 51566843 (Hong Kong) [UKRAINE-EO13661] [UKRAINE-EO13662] (Linked To: EN+ GROUP PLC).

General License 12

In connection with these designations, OFAC issued Full general License 12,3 which authorizes, through 12:01 a.m. eastern daylight time on June five, 2018, all transactions and activities otherwise prohibited past the Ukraine Related Sanctions Regulations that are "ordinarily incident and necessary to the maintenance or current of air downwardly of operations, contracts, or other agreements, including the importation of goods, services, or technology into the The states" involving one or more of the post-obit blocked persons and that were in effect prior to Apr six, 2018, subject area to sure exceptions:

  • AgroHolding Kuban
  • Basic Chemical element Limited
  • B-Finance Ltd.
  • EN+ Grouping PLC
  • JSC EuroSibEnergo
  • GAZGroup
  • Gazprom Burenie, OOO
  • Ladoga Menedzhment, OOO
  • NPV Technology Open up Joint Stock Company
  • Renova Grouping
  • Russian Machines
  • United Company RUSAL PLC
  • Any other entity in which ane or more of the above persons own, directly or indirectly, a l percent or greater involvement

General License 12 does non qualify the following activities:

  • The divestiture or transfer of debt, equity, or other holdings in, to, or for the benefit of the blocked persons listed above; 
  • Any transactions or dealings otherwise prohibited by any other part of OFAC'due south regulations, or any transactions or dealings with any blocked person other than the blocked persons listed in General License 12; 
  • The unblocking of any belongings blocked pursuant to any part of OFAC's regulations, except as specifically authorized by General License 12; or 
  • The exportation of goods from the United States.

Any payment to or for the straight or indirect benefit of a blocked person that is ordinarily incident and necessary to requite effect to a transaction authorized in Full general License 12 must exist fabricated into a blocked, interest-bearing account located in the United States.

US persons participating in transactions authorized by General License 12 are required to file with OFAC a comprehensive, detailed report of each transaction, including the names and addresses of parties involved, the type and scope of activities conducted, and the dates on which the activities occurred. The report is due within 10 business days after the expiration date of Full general License 12.

Full general License 13

OFAC also issued General License 13,4 which authorizes, through 12:01 a.m. eastern daylight time on May vii, 2018, all transactions and activities otherwise prohibited past the Ukraine Related Sanctions Regulations that are ordinarily incident and necessary to divest or transfer debt, equity, or other holdings in the following blocked persons to a non-US person, or to facilitate the transfer of debt, disinterestedness, or other holdings in the following blocked persons by a non-Us person to some other not-US person, field of study to sure exceptions:

  • EN+ Grouping PLC 
  • GAZ Grouping 
  • United Company RUSAL PLC

The activities authorized by Full general License thirteen include facilitating, clearing, and settling transactions to divest to a non-US person debt, equity, or other holdings in the blocked persons identified above, including on behalf of The states persons.

General License 13 does not authorize:

  • The unblocking of any property blocked pursuant to any part of OFAC's regulations, except as specifically authorized by Full general License xiii;
  • US persons to sell debt, equity, or other holdings to; to purchase or invest in debt, equity, or other holdings in; or to facilitate such transactions with, directly or indirectly, any person whose belongings and interests in property are blocked pursuant to the Ukraine Related Sanctions Regulations, including the blocked persons listed higher up;
  • Any transactions or dealings involving the property or interests in property of any person whose holding and interests in property are blocked pursuant to the Ukraine Related Sanctions Regulations other than the blocked persons listed in a higher place; or
  • Any transactions or dealings otherwise prohibited by whatever other part of OFAC's regulations.

US persons participating in transactions authorized by General License 13 are required to file with OFAC a comprehensive, detailed report of each transaction, including the names and addresses of parties involved, the type and scope of activities conducted, and the dates on which the activities occurred. The report is due within 10 business days after the expiration date of General License xiii.

OFAC Frequently Asked Questions

In connection with the above actions, OFAC published new frequently asked questions (FAQs) and an boosted revised FAQ regarding the Ukraine Liberty Back up Human activity (UFSA) on its website.5 In these FAQs, OFAC addresses the means in which these blocking designations might impact:

  • A US person employee or worker at an part of a company that was designated, or blocked pursuant to OFAC's 50 pct rule, on April 6, 2018; 
  • A US person who is an employee, or sits on the board, of an entity that was designated, or blocked pursuant to OFAC's 50 percent rule, on Apr 6, 2018; 
  • A U.s. company that has ordered goods from an entity that was designated, or blocked pursuant to OFAC's 50 pct rule, on Apr 6, 2018; 
  • An possessor of shares in, or global depositary receipts (GDRs) related to shares in, an entity that was designated or blocked pursuant to OFAC'south l per centum rule on Apr six, 2018; 
  • A Us person belongings accounts for or other property of an entity or private that was designated, or blocked pursuant to OFAC's 50 pct rule, on April 6, 2018; 
  • A United states of america company in which a person designated or blocked pursuant to OFAC's 50 percentage rule on April 6, 2022 holds an buying interest of less than l pct; and 
  • Foreign persons doing concern with the individuals or entities designated or blocked pursuant to OFAC's 50 per centum rule on April 6, 2018.

OFAC notes in the FAQs that, prior to Apr 6, 2018, EO 13662 only applied to OFAC's Ukraine-/Russiarelated sectoral sanctions and identifications nether the Sectoral Sanctions Identification (SSI) Listing. OFAC, notwithstanding, states that it may also designate persons every bit blocked nether EO 13662, and that, unlike with SSI entities, US persons must block the belongings and interests in property of any person designated as blocked pursuant to EO 13662.

OFAC also provided guidance in the FAQs regarding the definitions of "significant transactions" and "significant financial transactions" in the context of Department v of the UFSA.half-dozen Every bit amended past Section 226 of CAATSA, Department five of the UFSA requires mandatory sanctions on whatsoever persons facilitating pregnant transactions for certain defense- and free energy-related transactions and any persons facilitating meaning fiscal transactions for SDNs designated in connexion with the Ukraine-related sanctions.

OFAC volition consider the totality of the facts and circumstances in determining if a transaction is "meaning," including the following factors: (1) the size, number, and frequency of the transaction(due south); (2) the nature of the transaction(southward); (3) the level of awareness of management and whether the transaction(s) are part of a blueprint of behave; (4) the nexus between the transaction(south) and a blocked person; (5) the impact of the transaction(south) on statutory objectives; (half-dozen) whether the transaction(s) involve deceptive practices; and (7) such other factors that the Secretary of the Treasury deems relevant on a case-by-case basis. A transaction would not be considered pregnant if no specific license were required for a US person to participate in the transaction.

OFAC states that it will interpret "financial transaction" broadly to encompass any transfer of value involving a fiscal institution, including, only not limited to:

  • The receipt or origination of wire transfers;
  • The credence of commercial newspaper (both retail and wholesale), and the clearance of such paper (including checks and similar drafts); 
  • The receipt or origination of ACH or ATM transactions; 
  • The property of nostro, vostro, or loro accounts; 
  • The provision of merchandise finance or letter of credit services; 
  • The provision of guarantees or similar instruments; 
  • The provision of investment products or instruments or participation in investments; and 
  • Any other transactions for or on behalf of, straight or indirectly, a person serving as a correspondent, respondent, or beneficiary.

Additionally, OFAC will interpret the term "facilitated" broadly, to include the provision of help for certain efforts, activities, or transactions, including the provision of currency, financial instruments, securities, or whatever other transmission of value; purchasing; selling; transporting; swapping; brokering; financing; approving; guaranteeing; the provision of other services of any kind; the provision of personnel; or the provision of software, technology, or appurtenances of any kind.

Companies doing business relating to Russian federation should monitor closely whatever measures imposed by the U.s. to ensure compliance. Penalties for noncompliance can be severe.

Click here to download PDF

ane Please see our prior alerts on CAATSA, EO 13661, and EO 13662
2 A United states of america person is defined to include whatever U.s. citizen, permanent resident alien, entity organized nether the police southward of the United states of america or any jurisdiction west ithin the U.s.a. (including foreign branches), or person in the United States.
3 https://www.treasury.gov/resource-eye/sanctions/Programs/Documents/ukraine_gl12.pdf
four https://www.treasury.gov/resource-center/sanctions/Programs/Documents/ukraine_gl13.pdf
5 https://www.treasury.gov/resource-middle/faqs/Sanctions/Pages/faq_other.aspx#567
half-dozen Our alarm on the UFSA is available here

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