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ARTICLE · 26 JUNE 2024

OFAC Expands Secondary Sanctions Targeting FFIs Transacting With Sanctioned Russian Persons

Holland & Knight
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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.

United StatesInternational Law
Andres Fernandez
Andres Fernandez
Gabriel Caballero Jr.
Gabriel Caballero Jr.
Jacob Marco
Jacob Marco
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Highlights

  • 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.

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