U.S. imposes sanctions on foreign financial institutions helping Russia

12 June, 2024

In December, the White House said foreign financial institutions could be sanctioned if they worked with entities in Russia’s defense sector. Wednesday’s expansion of sanctions now means that those institutions could face sanctions if they work with almost any sanctioned Russian entity.

https://home.treasury.gov/news/press-releases/jy2404

[December 22 2023 ]

Typical sections:

“Sec. 11. (a) The Secretary of the Treasury, in consultation with the Secretary of State, and with respect to subsection (a)(ii) of this section, in consultation with the Secretary of State and the Secretary of Commerce, is hereby authorized to impose on a foreign financial institution the sanctions described in subsection (b) of this section, upon determining that the foreign financial institution has:

(i) conducted or facilitated any significant transaction or transactions for or on behalf of any person designated pursuant to section 1(a)(i) of this order for operating or having operated in the technology, defense and related materiel, construction, aerospace, or manufacturing sectors of the Russian Federation economy

(d) The Secretary of Homeland Security, with the concurrence of the Secretary of the Treasury, shall prescribe rules and regulations to collect, including through an authorized electronic data interchange system as appropriate, any documentation or information as may be necessary to enforce subsections (a)(i)(B)-(D) and (c) of this section as expeditiously as possible.”;

https://www.whitehouse.gov/briefing-room/presidential-actions/2023/12/22/executive-order-on-taking-additional-steps-with-respect-to-the-russian-federations-harmful-activities/

[December 13 2023 Treasury Sanctions for supplying Russia’s Military-Industrial Base ]

Treasury Imposes Sanctions on More Than 150 Individuals and Entities Supplying Russia’s Military-Industrial Base

Treasury said it hit more than 150 people and companies with punitive measures, targeting third-country military procurement networks that have helped Russia acquire machine tools, key technologies and equipment for the Kremlin’s industrial base.

https://home.treasury.gov/news/press-releases/jy1978

https://ofac.treasury.gov/recent-actions/20231212

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