Blocking Sanctions on VTB Bank and Other Major Russian Financial

Institutions

• OFAC announced the blocking/designation of a number of major Russian financial institutions and their subsidiaries. These designations were made pursuant to EO 14024 and included:
• VTB Bank Public Joint Stock Company (“VTB Bank”), “which holds nearly 20 percent of banking assets in Russia” and is “one of the largest financial institutions” OFAC has ever blocked. OFAC also designated/ blocked 20 VTB bank subsidiaries (in Russia and eight other countries) for being directly or indirectly owned or controlled by VTB Bank.
• Public Joint Stock Company Bank Financial Corporation Otkritie (“Otkritie”) and 12 of its subsidiaries.
• Open Joint Stock Company Sovcombank (“Sovcombank) and 22 of its subsidiaries.
• Joint Stock Commercial Bank Novikombank (“Novikombank”).

As with almost all OFAC blocked individuals and entities, any entity directly or indirectly owned 50 percent or more, whether individually or in the aggregate, by any of these banks or their subsidiaries is also blocked.

What to do: These designations are effective immediately, and all US persons should screen their suppliers, customers, and third-party business partners – in addition to their ultimate beneficial owners – against the new SDN List containing these entities.