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By: Danielle Wright

CommentTuesday - July 29, 2014

138_115_question_mark.jpgQ: I understand that OFAC recently published a new list of Russian and Ukrainian sanction targets in response to the crisis in Crimea.  How should credit unions deal with these new OFAC targets?

A: The Office of Foreign Assets Control (OFAC) published a new list on July 16 targeting certain entities operating in the financial services, energy, arms and related sectors of the Russian economy in accordance with Executive Order (E.O.) 13662. The Sectoral Sanctions Identifications (SSI) List is not part of the Specially Designated Nationals (SDN) List, although some SSI targets may appear on the SDN List.

The 7/16 sanctions were imposed on: two major Russian financial institutions (Gazprombank OAO and VEB), two Russian energy firms; eight Russian arms firms; the “Luhansk People’s Republic” and the “Donetsk People’s Republic,” which have asserted governmental authority over parts of Ukraine without the authorization of the Government of Ukraine, and the self-declared prime minister of the Donetsk People’s Republic; a key shipping facility in the Crimean peninsula (Feodosiya Enterprises); and several Russian government officials.  

The Ukraine-related sanctions also added Russian and Ukrainian individuals and entities to the SDN List.  As the crisis continues, OFAC will likely add more individuals and entities on the SDN List and/or SSI List.

So, how should CUs handle these new OFAC targets? First, check with your OFAC software vendor to make sure they’re tracking this list in addition to the SDN List.

As for whether to block property or reject transactions involving these new targets, OFAC has a list of rather complicated frequently asked questions on how to handle SSIs (see resource links below).  But, here’s the nutshell version from what I can tell: U.S. persons are prohibited from providing debt financing longer than 90 days or new equity to any person/entity on the SSI List. However, targets’ assets under U.S. jurisdiction are not “blocked” (frozen) at this time. 

Obviously, this post just hits the highlights – see the resource links for more information and call OFAC if you get a hit on the SSI List. 

Resource Links:


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