Back in February of 2022, the U.S. Treasury took significant action in response to Russia’s continued aggression in Ukraine. To help deter Russia from continuing down the same path, the U.S. Office of Foreign Assets Control decided to initiate specific sanctions against some of the country’s largest financial institutions. The sweeping OFAC sanctions targeted an overwhelming 80% of all Russian banking assets, including VTB Bank Europe.

These actions were taken as a result of Executive Order 14024. The reasoning behind the sanctions, according to the Order, is that Russia had allegedly been violating the core principles of international law by showing disrespect towards the territorial integrity of sovereign states, most notably Ukraine.

As part of the OFAC sanctions, the Treasury also included specific Russian political figures, family members of Russian elites, and Russian-state owned enterprises. These unprecedented actions severely limited Russia’s ability to conduct business and cut off many parts of the Russian financial system from the U.S. economy.

While a lot of destruction has already taken place, on April 2nd, 2024, the OFAC updated their specifically designated nationals list and deleted the following entities:

• VTB Bank Europe
• VTB Bank Deutschland
• OST-West Handelsbank AG

Further, on April 22nd, the OFAC issued General License No. 94, which authorizes transactions involving VTB Bank Europe and entities owned by it.

Are You Aware of OFAC’s Sanctions List?

Does your business operate internationally or take on various global clients? If so, then it’s extremely important for you to be aware of OFAC’s sanctions list. Conducting any type of business with a sanctioned individual or entity will be taken extremely seriously under the law. OFAC Sanctions are put into place to protect the U.S., and any violation is considered not only a threat to national security but also a potential threat to our country’s foreign relations.

If you’re caught doing business with a sanctioned individual or entity, then you could face a sentence of up to 30 years in prison. You’ll also likely get heavily fined.

Depending on the nature of the violation, you could face fines of several millions of dollars. An intense investigation will be conducted regarding your business’s operations, and there’s a good chance that your business won’t survive an OFAC audit that results in a criminal charge.

All that said, legally complying with the OFAC sanction list is necessary for your business’s survival. You can do an online search to directly determine if a potential client is currently being sanctioned. You can also consider speaking with an international attorney who can help you go over your specific rights, obligations, and duties as an international business.

Here at Bukh Global, our team of experienced lawyers can help you navigate OFAC sanctions and other legal issues to ensure your business remains compliant.

Schedule a call with our team of international lawyers now if you have more questions about how to navigate OFAC sanctions, global laws, potential criminal charges, or another legal matter regarding your business.