Morgan Lewis US and Russia Sanctions Update
US Sectoral Sanctions
Sanctions - OFAC
Finance / Capital Markets
The OFAC SSI sanctions prohibit without license:
-
Per Directive 1 (as amended / effective Nov. 2017, per CAATSA addition): new debt
financing with maturity of >14 days (revised down from >30 days), or new equity
financing, for these designated entities or their subs (≥50%-owned), and transactions with
or dealing in such debt or equity
•
Bank of Moscow (now merged into VTB)
•
Gazprombank
•
Russian Agricultural Bank (Rosselkhozbank)
•
Sberbank
.
VEB
.
VTB
(except depositary receipts based on pre-existing shares - per FAQ 391)
And note OFAC's expanded bank SSIs List (by several additions to date)
singling out many specific VEB, VTB, Sberbank, Gazprombank and Russian Agricultural Bank
subs/affiliates in Russia, Europe, and elsewhere
-
all of these were technically covered already under the 50%+ ownership rule - so they are also
named/singled out just for emphasis / clarity, to help stop circumvention, etc.
but note that now any of these named subs would need specific OFAC delisting if/when no longer
50%+ owned by its "named SSI parent"
e.g., Russian Direct Investment Fund (RDIF) - no longer a VEB sub, but still on SSI List
as opposed to, for example, Estonia's Coop Bank (formerly Estonian Credit Bank) delisted in 2018
following 2017 buyout by Coop Eesti from VTB
Morgan Lewis
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