Russia Sanctions Compliance Guidelines Get Fresh Upgrade
In a move aimed at reinforcing its stance against Russia’s perceived transgressions, the White House has signed an executive order that takes aim at Moscow’s nefarious activities. In tandem with this development, the US Treasury Department’s Office of Foreign Assets Control (OFAC) is releasing a slew of updated guidelines and advisories designed to ensure foreign financial institutions remain in compliance with the latest Russia sanctions.
Key Updates and New Regulations
The fresh set of directives comes on the heels of December 22, 2023’s executive order that further expanded upon the original sanctions package implemented back in 2022. OFAC has taken it upon itself to publish a raft of new regulations aimed at curbing Moscow’s influence and limiting its ability to carry out illicit activities.
New General Licenses
- GL83: Allows for specific transactions related to fish imports from Russia
- GL84: Permits the closure of correspondent or payable-through accounts
- GL85: Enables the winding down of business with Expobank Joint Stock Company
Additional Clarification through FAQs
OFAC has released 12 new frequently asked questions (FAQs 1146-1157) that provide additional clarification on how to navigate these sanctions. These FAQs offer a better understanding of the requirements and regulations set forth by OFAC.
Compliance Advisory for Foreign Financial Institutions
In a bid to offer practical guidance to foreign financial institutions navigating this complex landscape, OFAC has published a compliance advisory. This detailed document provides a comprehensive rundown of the changes made to E.O. 14024 and offers actionable advice on how to identify and mitigate potential sanctions risks.
Preventing Unintentional Non-Compliance
By providing such clarity, the US aims to prevent unintentional non-compliance and promote a smoother implementation process for financial institutions worldwide.
As Washington continues to tighten its grip on Moscow’s activities, it remains to be seen whether Russia will comply with these directives or resist further pressure from the international community. One thing is certain, however: foreign financial institutions will need to stay up-to-date on the latest sanctions regulations if they hope to avoid falling foul of US laws and regulations.