OFAC Update: New Executive Order; Russia-related Designations and Designations Updates; Issuance of Russia-related General Licenses
 
The Office of Foreign Assets Control (OFAC) published Executive Order (E.O.) of April 6, 2022 “Prohibiting New Investment in and Certain Services to the Russian Federation in Response to Continued Russian Federation Aggression”, to ban all new investment in Russia by U.S. persons, wherever located. Similar to E.O.s 14066 and 14068 - which prohibit imports and exports of goods and services of certain products and categories involving Russia - this new E.O. also authorizes the Secretary of the Treasury to ban the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of any category of services. Further, OFAC issued 6 General Licenses that temporarily allow certain operations that would otherwise be prohibited under the new sanctions. 
 
In addition, OFAC has blocked Public Joint Stock Company Sberbank of Russia (Sberbank) and 42 of its subsidiaries, which is uniquely important to the Russian economy, holding about a third of all bank assets in Russia. Sberbank is the largest financial institution in Russia and is majority-owned by the Government of the Russia (GoR). OFAC is also imposing full blocking restrictions on Joint Stock Company Alfa-Bank (Alfa-Bank) and 6 of its subsidiaries, Russia’s largest privately-owned financial institution and Russia’s fourth-largest financial institution overall.
 
All entities owned 50 percent or more, directly or indirectly, by Alfa-Bank or Sberbank are subject to blocking under E.O. 14024, even if not designated by OFAC.
 
OFAC’s new sanctions against Russia pose new compliance challenges. Certain activity involving Russia may require additional due diligence to identify prohibited new investment in Russia and certain prohibited products and categories.
Harry Cupp - Chair 
VP, FCB Risk Manager
Sunwest Bank
Guillermo Horta - Chair
Chief AML Officer & Global Head
Scotiabank
David Schwartz
President & CEO
FIBA
Gabriel Caballero Jr.
Partner at Holland & Knight
Following Russia’s invasion of Ukraine, consequences in the form of sanctions have been issued at a fast and furious pace. This has led to challenges for the financial services industry to keep up with the flurry of Executive Orders, Directives, General Licenses, and FAQs.
April 20, 2022
10:00 AM - 11:30 AM (EST)

FIBA Training Center
80 SW 8th Street - Suite 2170
OR VIA ZOOM
This hybrid event has been approved for 1.5 hours of continuing education credits.
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