RUSSIA SANCTIONS: US TREASURY TAKES AIM AT FOUNDATIONAL FINANCIAL INFRASTRUCTURE AND ACCESS TO THIRD COUNTRY SUPPORT

On 12 June, the US Treasury advised that it is issuing sweeping new measures guided by G7 commitments to intensify the pressure on Russia for its war against Ukraine. It is increasing the risk of secondary sanctions for foreign financial institutions that deal with Russia’s war economy; restrict the ability of Russian military-industrial base to take advantage of certain US software and information technology (IT) services; and, together with the Department of State, target more than 300 individuals and entities both in Russia and outside its borders — including in Asia, the Middle East, Europe, Africa, Central Asia, and the Caribbean — whose products and services enable Russia to sustain its war effort and evade sanctions.  The US Treasury is targeting the architecture of Russia’s financial system, which has been reoriented to facilitate investment into its defence industry and acquisition of goods needed to further its aggression against Ukraine. 

OFAC has updated the information for 5 sanctioned Russian financial institutions, to include the addresses and aliases of their foreign locations.

The State Department is targeting over 100 entities and individuals engaged in the development of Russia’s future energy, metals, and mining production and export capacity; sanctions evasion and circumvention; and furthering Russia’s ability to wage its war against Ukraine.

The US Treasury and State Department have issued a new determination which prohibits the supply to any person in the Russian Federation of IT consultancy and design services; and IT support services and cloud-based services for enterprise management software and design and manufacturing software.  The determination will take effect on 12 September.

The news release also warns that foreign financial institutions risk being sanctioned for conducting or facilitating significant transactions, or providing any service, involving any blocked person, including designated Russian banks.

OFAC is publishing an updated Compliance Advisory to Foreign Banks on Russia Sanctions Risks in order to provide additional guidance for Foreign Financial Institutions. 

OFAC is also issued 8 new General Licenses; together with 8 new FAQ and 10 amended FAQ.

https://ofac.treasury.gov/recent-actions/20240612

https://home.treasury.gov/news/press-releases/jy2404

https://ofac.treasury.gov/media/932951/download?inline

https://ofac.treasury.gov/media/932436/download?inline

https://kpmg.com/us/en/home/insights/2024/06/tnf-ofac-russia-related-determinatrions-general-licenses-faqs.html

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Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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