United States targeting entities and individuals evading sanctions on Russia

The designated entities and individuals have been involved in attempts to evade sanctions imposed on Russia.

U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC)

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) today issued:

  • Russia-related General License 28 [PDF 140 KB]—Authorizing certain transactions involving public joint stock company Transkapitalbank and Afghanistan
  • Russia-related General License 29 [PDF 259 KB]—Authorizing the wind down of transactions involving public joint stock company Transkapitalbank
  • An updated list of specially designated nationals (SDN list)
  • A new "frequently asked question" (FAQ) (full text provided below)

According to a Treasury release, the designated entities and individuals have been involved in attempts to evade sanctions imposed by the United States and its international partners on Russia.
 

Text of FAQ

1030. What obligations do operators of credit card systems have under the Russian Harmful Foreign Activities Sanctions Regulations, 31 C.F.R. part 587 (RuHSR), and the Belarus Sanctions Regulations, 31 C.F.R. part 548 (BSR), with regard to payment cards issued by sanctioned Russian financial institutions?

Pursuant to the RuHSR and BSR, U.S. persons, including U.S. operators of credit card systems and U.S. acquirers, are prohibited from processing transactions involving certain sanctioned foreign financial institutions, unless exempt or authorized by OFAC.  Non-U.S. operators of credit card systems whose payment cards are issued by sanctioned foreign financial institutions may also be in violation of OFAC-administered sanctions regulations if they allow those cards to be used in the United States.

OFAC encourages U.S. persons, including U.S. operators of credit card systems and U.S. acquirers, to exercise caution and due diligence in dealing with non-U.S. operators of credit card systems that are known to host payment cards issued by sanctioned foreign financial institutions and whose payment cards are accepted in the United States.  Examples of due diligence measures may include requesting Bank Identification Numbers (BINs) associated with sanctioned foreign financial institutions, disabling those BINs from operation in the United States, and requesting that non-U.S. operators of credit card systems prevent the use of payment cards issued by sanctioned foreign financial institutions in the United States at the network level.


For more information on sanctions and other responses to Russia’s war on Ukraine, visit KPMG’s dedicated website.


Contact a professional with KPMG’s Trade & Customs services:

Doug Zuvich
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Principal and East Coast Leader
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Partner and National Practice Leader
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Steve Brotherton
Principal and Global Export and Sanctions Leader
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Luis (Lou) Abad
Principal, Washington National Tax
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Irina Vaysfeld
Principal
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Amie Ahanchian
Principal
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Christopher Young
Principal
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Gisele Belotto
Principal
E: gbelotto@kpmg.com

George Zaharatos
Principal
E: gzaharatos@kpmg.com

Andy Doornaert
Managing Director
E: adoornaert@kpmg.com

Jessica Libby
Principal
E: jlibby@kpmg.com

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