Companies Must Review Compliance Policies Following New Sanctions of Russian Financial Institutions and Individuals

In response to Russia’s anticipated and then executed invasion of Ukraine, last week the U.S. Department of Treasury ("Treasury") announced two new rounds of economic sanctions against Russian-connected financial institutions and individuals.

On February 22, 2022, the Treasury announced sanctions against two major Russian state-owned financial institutions and certain individuals. These sanctions were issued in response to Russia’s recognition of two Ukrainian regions as independent states. These initial measures prohibited U.S. individuals and businesses from doing business with and froze the assets of two Russian financial institutions with ties to the Kremlin and Russian military. They also instituted full blocking sanctions on five individuals related to the Kremlin and these financial institutions.

Following the Russian invasion of Ukraine, on February 24, 2022, the Treasury announced significantly more expansive sanctions against the top ten Russian financial institutions. The Treasury’s Office of Foreign Assets Control (“OFAC”) targeted nearly 80 percent of all banking assets in Russia. This includes Russia’s two largest financial institutions – Sberbank and VTB Bank. These sanctions also prohibit certain transactions and dealings between Russian state-owned enterprises and U.S. persons and target the assets of more Kremlin-connected individuals. The U.S. has coordinated in this effort with global partners taking similar actions.

OFAC’s enforcement of these new sanctions is expected to be aggressive. It is important to review your company’s existing compliance policies and practices to ensure alignment with these new restrictions, and make sure that your business is not unintentionally facilitating any activities prohibited by these new sanction regimes.

Recent Posts

Porter Hedges LLP Cookie Preference Center

Your Privacy

When you visit our website, we use cookies on your browser to collect information. The information collected might relate to you, your preferences, or your device, and is mostly used to make the site work as you expect it to and to provide a more personalized web experience. For more information about how we use Cookies, please see our Privacy Policy.

Strictly Necessary Cookies

Always Active

Necessary cookies enable core functionality such as security, network management, and accessibility. These cookies may only be disabled by changing your browser settings, but this may affect how the website functions.

Functional Cookies

Always Active

Some functions of the site require remembering user choices, for example your cookie preference, or keyword search highlighting. These do not store any personal information.

Form Submissions

Always Active

When submitting your data, for example on a contact form or event registration, a cookie might be used to monitor the state of your submission across pages.

Performance Cookies

Performance cookies help us improve our website by collecting and reporting information on its usage. We access and process information from these cookies at an aggregate level.

Powered by Firmseek