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U.S. Sanctions additional Russian nationals and entities, extending certain transactions for a limited time

December 15, 2022, the OFAC has (i) updated SDN list and (ii) issued several General Licenses.

Updates of OFAC SDN list

Among others, the updates list includes oligarch Vladimir Potanin and his family members were added to SDN OFAC list, thus introducing new wave of sanctions imposed towards Russian energy sector. Together with Vladimir Potanin, several of his companies (including INTERROS, ROSBANK) were also included in the list[1].

Concerning ROSBANK, two General Licenses (No. 58[2] and 59[3]) were issued, thus authorizing certain wind-up transactions with it until mid-March 2023.

As for Norilsk Nickel (NORNICKEL), another company partly owned by Vladimir Potanin, there is an explicit OFAC guidance (FAQ # 1104) that NORNICKEL is not under sanctions.

Extension of General License with transactions related to energy.

Besides, OFAC issued a General License No. 8E[4] in extension to authorized crucial energy-related transactions with SND sanctioned Russian banks, namely:

  • State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank;
  • Public Joint Stock Company Bank Financial Corporation Otkritie;
  • Sovcombank Open Joint Stock Company;
  • Public Joint Stock Company Sberbank of Russia;
  • VTB Bank Public Joint Stock Company;
  • Joint Stock Company Alfa-Bank;
  • Public Joint Stock Company Rosbank;
  • Any entity in which one or more of the above persons own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest; or
  • the Central Bank of the Russian Federation.

The General License No. 8E was issued until May 16, 2023 and renewed previous General License No. 8D dated November 10, 2022 that has not included ROSBANK.

[1] Updated SDN list is found at: https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20221215.

[2] General Licence No. 58 Authorizing the Wind Down and Rejections Involving Public Joint Stock Company Rosbank is found at: https://home.treasury.gov/system/files/126/russia_gl58.pdf.

[3] General Licence No. 59 Authorizing Transactions Related to Debt or Equity of, or Derivative Contracts Involving Public Joint Stock Company Rosbank is found at: https://home.treasury.gov/system/files/126/russia_gl59.pdf.

[4] General Licence No. 8E Authorizing Transactions Related to Energy is found at: https://home.treasury.gov/system/files/126/russia_gl8e.pdf.