This second wave of OFAC’s sanctions come at various speeds and depths. It targets SBERBANK, Russia’s largest bank, prohibiting correspondent and payable-through account transactions. Yet, it does not issue a full blocking order for Sberbank. 

On the opposite end is VTB Bank, Russia’s second largest bank, which sees full blocking sanctions. 

As to major newcomers under OFAC’s Directive 3, it features Alfa-Bank, Russia’s largest privately owned bank or State-owned Alrosa, one of World’s biggest Diamond companies. 

Under a separate regime, the PEESA (Protecting Europe's Energy Security Act), OFAC does sanction Swiss registered Nord Stream 2 and Matthias Warnig, its CEO. 

A range of other sanctions are being rumoured through press and officials’ declarations, however, as of today, we are not aware of other OFAC lead initiatives. 

Additional restrictions are published by the Department of Commerce on dual-use and military end users export restrictions. 

For the full list and details please ask our analysts at team@polixis.com.