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ARTICLE · 12 SEPTEMBER 2024

OFAC Takes Coordinated Action On Russia

Buchanan Ingersoll & Rooney
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On September 4, 2024, the U.S. Department of the Treasury Office of Foreign Assets Control (OFAC) issued an alert that Russian companies are attempting to evade U.S. sanctions by creating...

GlobalInternational Law
Amanda L. Wetzel
Amanda L. Wetzel
Daniel B. Pickard
Daniel B. Pickard
Milton I. Koch
Milton I. Koch
Richard Montes de Oca
Richard Montes de Oca
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An Alert on Russian Financial Institutions' Sanctions Evasion is Issued, a General License is Issued, and Russian Individuals and Organizations Related to Efforts to Influence the 2024 U.S. Presidential Election are Sanctioned1

On September 4, 2024, the U.S. Department of the Treasury Office of Foreign Assets Control (OFAC) issued an alert that Russian companies are attempting to evade U.S. sanctions by creating new branches or subsidiaries of Russian financial institutions in third countries. OFAC warns foreign parties that there are "significant sanctions risks associated with facilitating Russia's efforts to evade sanctions." Companies should be careful regarding any business dealings with overseas subsidiaries of Russian financial institutions, including indirect activities such as payment processing or trade finance. Under Executive Order 14024, OFAC has sanctioned foreign financial institutions that conduct or facilitate any significant transaction or provide

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