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Alert: OFAC Expands Secondary Sanctions Targeting FFIs Transacting with Sanctioned Russian Persons

Holland & Knight sent this email to their subscribers on June 24, 2024.

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June 24, 2024

 

OFAC Expands Secondary Sanctions Targeting FFIs Transacting with Sanctioned Russian Persons

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced updated guidance expanding the categories of transactions subjecting Foreign Financial Institutions (FFIs) to U.S. secondary sanctions.

Since Dec. 22, 2023, FFIs have been subject to secondary sanctions risk for conducting or facilitating certain transactions involving "Russia's military-industrial base" or related sectors. The revised definition broadens the definition of "Russia's military-industrial base" to include all persons designated under Executive Order 14024.

This expansion of secondary sanctions authority signals a potentially more aggressive approach against parties perceived to be facilitating evasion of U.S. sanctions targeting Russia and significantly raises the level of sanctions risk for FFIs continuing to operate in Russia.​

Read the full article »

 

Contact the Authors

Andres Fernandez

Miami
305.789.7433
[email protected]

Gabriel Caballero Jr.

Miami
305.789.7442
[email protected]

Jacob Marco

Philadelphia
215.252.9607
[email protected]

   


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Holland & Knight LLP | Operations Center | 524 Grand Regency Blvd. | Brandon, FL 33510-3931 | www.hklaw.com

 

Text-only version of this email

Holland & Knight www.hklaw.com JUNE 24, 2024 OFAC EXPANDS SECONDARY SANCTIONS TARGETING FFIS TRANSACTING WITH SANCTIONED RUSSIAN PERSONS The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced updated guidance expanding the categories of transactions subjecting Foreign Financial Institutions (FFIs) to U.S. secondary sanctions. Since Dec. 22, 2023, FFIs have been subject to secondary sanctions risk for conducting or facilitating certain transactions involving "Russia's military-industrial base" or related sectors. The revised definition broadens the definition of "Russia's military-industrial base" to include all persons designated under Executive Order 14024. This expansion of secondary sanctions authority signals a potentially more aggressive approach against parties perceived to be facilitating evasion of U.S. sanctions targeting Russia and significantly raises the level of sanctions risk for FFIs continuing to operate in Russia. Read the full article » Contact the Authors ANDRES FERNANDEZ Miami 305.789.7433 [email protected] GABRIEL CABALLERO JR. Miami 305.789.7442 [email protected] JACOB MARCO Philadelphia 215.252.9607 [email protected] More insights are available on our website. Connect With Us You are currently subscribed to receive Holland & Knight publications as . Your email address is never shared with any third parties. For more information about our privacy practices, please view the Holland & Knight Privacy Notice. To learn how to prevent these communications from [email protected] being intercepted by your spam filter, click here. Visit my subscription management to change your account preferences or . If this email was forwarded to you, and you would like to begin receiving this or any other Holland & Knight publication directly, please . The information provided herein presents general information and should not be relied on as legal advice when analyzing and resolving a specific legal issue. If you have specific questions regarding a particular fact situation, please consult with competent legal counsel about the facts and laws that apply. Copyright © 2024 Holland & Knight LLP All Rights Reserved Holland & Knight LLP | Operations Center | 524 Grand Regency Blvd. | Brandon, FL 33510-3931 | www.hklaw.com  
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