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OFAC Sanctions Against Russia in Response to Actions in the Donetsk and Luhansk Regions

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The gin is out: the first major round of OFAC sanctions is here. Here is what you need to know in a nutshell: 

  • OFAC targets Russia’s Sovereign Debt, via sanctioning VEB bank, a major state-owned institution along with its 25 subsidiaries.  Important to note, VEB has been under OFAC’s Sectoral Sanctions Identification (SSI) list since 2014! The current round is about Specially Designated Nationals (SDN) list, much tougher with asset freezing and business ban. 
  • Second Important case is Promsvyazbank, formerly privately owned and in 2018 nationalized institution, heavily exposed to serving the defense sector. The bank has also been providing correspondent banking services to many smaller CIS banks. 
  • OFAC add-ups to the so-called Non-SDN Menu-Based Sanctions List are 3 key Russian State affiliated institutions: the Central Bank of Russia, Ministry of Finance and the National Wealth Fund. 
  • The Non-SDN Menu-Based Sanctions List is not a typical SDN type of list. It is somewhat “less sanctioned” creation that in OFAC’s terms is “less than full blocking sanctions, and may include, among other things, non-blocking prohibitions on the provision of certain goods or services and blocking prohibitions subject to a statutory exception for the importation of goods.”
  • The imposition of Donetsk & Luhansk Sanctions, despite their scary “blanket nature” are de facto mild irrelevant sanctions to global banking, since actual exposure to the region has been dramatically reduced in 2014/2015. 
  • OFAC, inter alia, sanctions 3 key Russian PEPs, along with several of their family members. 

The above-mentioned sanctions technically impact less than 100 entities. However, the actual collateral sanction exposure might be in thousands. 

Conclusion: despite the fact that this is the toughest sanctions yet this year, overall, it looks as if it is the first “mild” wave with lots of room to act for more, should the situation on the ground worsen.