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Here it comes (Part 1 of ?): OFAC makes Russia and Belarus designations… etc.

OFAC has added the following persons:

IVANOV, Sergei Sergeevich (Cyrillic: ИВАНОВ, Сергеи Сергеевич) (a.k.a. IVANOV JR., Sergey; a.k.a. IVANOV, Sergey Sergeevich), 12 BLD 1 Rochdelskaya Street Apt 13, Moscow 123002, Russia; DOB 23 Oct 1980; POB Moscow, Russia; nationality Russia; Gender Male; Passport 759511560 (Russia) issued 29 Oct 2018 expires 29 Oct 2028 (individual) [RUSSIA-EO14024] (Linked To: IVANOV, Sergei Borisovich). 

PATRUSHEV, Andrey (Cyrillic: ПАТРУШЕВ, Андрей), St. Petersburg, Russia; DOB 1981; POB Saint Petersburg, Russia; nationality Russia; Gender Male (individual) [RUSSIA-EO14024] (Linked To: PATRUSHEV, Nikolai Platonovich).

PUCHKOV, Andrey Sergeyevich (Cyrillic: ПУЧКОВ, Андрей Сергеевич) (a.k.a. PUCHKOV, Andrei; a.k.a. PUCHKOV, Andrei Sergeevich; a.k.a. PUCHKOV, Andrey), Russia; DOB 23 Jan 1977; POB Moscow, Russia; nationality Russia; Gender Male; Tax ID No. 771910226809 (Russia) (individual) [RUSSIA-EO14024].

SECHIN, Ivan Igorevich (a.k.a. SECHIN, Ivan (Cyrillic: СЕЧИН, Иван)), Moscow, Russia; Shvedskiy Typik 3 KV38, Moscow 125009, Russia; DOB 03 Jan 1989; POB St. Petersburg, Russia; nationality Russia; Gender Male; Passport 722759197 (Russia) issued 24 Jan 2013 expires 24 Jan 2023 (individual) [RUSSIA-EO14024] (Linked To: SECHIN, Igor Ivanovich).

SOLOVIEV, Yuriy Alekseyevich (Cyrillic: СОЛОВЬЕВ, Юрий Алексеевич) (a.k.a. SOLOVIEV, Yuri; a.k.a. SOLOVIEV, Yuri Alekseievich; a.k.a. SOLOVYEV, Yury; a.k.a. SOLOVYOV, Yury), Russia; DOB 13 Apr 1970; POB Ulanbataar, Mongolia; nationality Russia; alt. nationality United Kingdom; Gender Male (individual) [RUSSIA-EO14024].

ULYUTINA, Galina Olegovna (a.k.a. SOLOVIEVA, Galina Olegovna; a.k.a. ULYUTINA, Galina), 8-1-60 Philippovskiy, Moscow 119019, Russia; DOB 20 Oct 1977; POB Avdeevka, Ukraine; nationality Russia; alt. nationality Bulgaria; Gender Female; National ID No. 4510519178 (Russia); alt. National ID No. 7710206574 (Bulgaria) (individual) [RUSSIA-EO14024] (Linked To: SOLOVIEV, Yuriy Alekseyevich).

VEDYAKHIN, Alexander Aleksandrovich (Cyrillic: ВЕДЯХИН, Александр Александрович) (a.k.a. VEDYAKHIN, Aleksandr; a.k.a. VEDYAKHIN, Alexander), Russia; DOB 20 Feb 1977; POB Volgograd, Russia; nationality Russia; Gender Male; Passport 531179415 (Russia); National ID No. 1801541495 (Russia) (individual) [RUSSIA-EO14024].

and entities:

AKTSIONERNOE OBSHCHESTVO FINTENDER (a.k.a. AO FINTENDER; a.k.a. FINTENDER JOINT STOCK COMPANY; a.k.a. FINTENDER JSC), Pr-Kt Tekstilshchikov D. 46, Pomeshch. 1, Kom.56, Kostroma 156000, Russia; Tax ID No. 7743113487 (Russia); Registration Number 1157746705930 (Russia) [RUSSIA-EO14024] (Linked To: SOVCOMBANK OPEN JOINT STOCK COMPANY). 

AKTSIONERNOE OBSHCHESTVO RTS-KHOLDING (a.k.a. AO RTS-KHOLDING; a.k.a. RTS-HOLDING JOINT STOCK COMPANY; a.k.a. RTS-HOLDING JSC), Nab. Tarasa Shevchenko D. 23A, Ofisnoe Zd. Bashnya-2000, Moscow 121151, Russia; Website fintender.ru; Tax ID No. 7723825581 (Russia); Registration Number 1127746030411 (Russia) [RUSSIA-EO14024] (Linked To: SOVCOMBANK OPEN JOINT STOCK COMPANY).

AKTSIONERNOE OBSHCHESTVO SOVKOMBANK STRAKHOVANIE (a.k.a. AO SOVKOMBANK STRAKHOVANIE; a.k.a. SOVCOMBANK INSURANCE JSC), Pr-Kt Moskovskii D.79a, Lit.A, Saint Petersburg 196084, Russia; Website kfins.ru; Tax ID No. 7812016906 (Russia); Registration Number 1027810229150 (Russia) [RUSSIA-EO14024] (Linked To: SOVCOMBANK OPEN JOINT STOCK COMPANY).

BANCO VTB AFRICA SA (a.k.a. VTB AFRICA), 22, Rua da Missao, Luanda, Angola; SWIFT/BIC VTBLAOLU; Website www.vtb.ao; Executive Order 13662 Directive Determination - Subject to Directive 1; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives [UKRAINE-EO13662] [RUSSIA-EO14024] (Linked To: VTB BANK PUBLIC JOINT STOCK COMPANY).

BANK NATIONAL FACTORING COMPANY JOINT STOCK COMPANY (a.k.a. BANK NATIONAL FACTORING COMPANY JSC; a.k.a. BANK NFC JOINT STOCK COMPANY; a.k.a. "BANK NFC JSC"), 14 Ul Kozhevnicheskaya, Moscow 115114, Russia; Tax ID No. 7722159794 (Russia); Registration Number 1027700385954 (Russia) [RUSSIA-EO14024] (Linked To: SOVCOMBANK OPEN JOINT STOCK COMPANY).

BANK VTB KAZAKHSTAN JOINT STOCK COMPANY (a.k.a. BANK VTB KAZAKHSTAN JSC; a.k.a. JOINT STOCK COMPANY VTB BANK KAZAKHSTAN; a.k.a. SUBSIDIARY JSC BANK VTB KAZAKHSTAN), 28 Timiryazev Street, Almaty 050040, Kazakhstan; SWIFT/BIC VTBAKZKZ; Website http://en.vtb-bank.kz/; Executive Order 13662 Directive Determination - Subject to Directive 1; Target Type Financial Institution; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives [UKRAINE-EO13662] [RUSSIA-EO14024] (Linked To: VTB BANK PUBLIC JOINT STOCK COMPANY).

BEST2PAY LIMITED, Ul. Professora Popova D. 37, Lit. Shch, Pomeshch. 1-N (Komn.127), Saint Petersburg 197022, Russia; Website best2pay.net; Tax ID No. 7813531811 (Russia); Registration Number 1127847218674 (Russia) [RUSSIA-EO14024] (Linked To: SOVCOMBANK OPEN JOINT STOCK COMPANY).

BM BANK PUBLIC JOINT STOCK COMPANY (a.k.a. AKTSIONERNOE OBSHCHESTVO BM BANK; f.k.a. AKTSIONERNY KOMMERCHESKI BANK BANK MOSKVY OTKRYTOE AKTSIONERNOE OBSCHCHESTVO; f.k.a. BANK MOSKVY PAO; f.k.a. BANK OF MOSCOW; a.k.a. BM BANK AO; a.k.a. BM BANK JSC; f.k.a. JOINT STOCK COMMERCIAL BANK - BANK OF MOSCOW OPEN JOINT STOCK COMPANY; a.k.a. PAO BM BANK), Bld 3 8/15, Rozhdestvenka St., Moscow 107996, Russia; SWIFT/BIC MOSWRUMM; Website www.bm.ru; BIK (RU) 044525219; Executive Order 13662 Directive Determination - Subject to Directive 1; Target Type Financial Institution; Government Gazette Number 29292940 (Russia); Registration Number 1027700159497 (Russia); All offices worldwide; for more information on directives, please visit the following link: https://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives [UKRAINE-EO13662] [RUSSIA-EO14024] (Linked To: VTB BANK PUBLIC JOINT STOCK COMPANY).

BUSINESS-FINANCE LIMITED LIABILITY COMPANY (a.k.a. "BUSINESS-FINANCE"; a.k.a. "BUSINESS-FINANCE LLC"), Ul. Myansnitskaya D. 35, Moscow 101000, Russia; Target Type Financial Institution; Tax ID No. 7707572492 (Russia); Registration Number 1057749598169 (Russia) [RUSSIA-EO14024] (Linked To: VTB BANK PUBLIC JOINT STOCK COMPANY).

GMCS MANAGEMENT LIMITED LIABILITY COMPANY (a.k.a. GMCS MANAGEMENT LIMITED; a.k.a. GMCS MANAGEMENT LLC; a.k.a. GMCS MANAGEMENT LTD), Ul. Pokryshkina D. 7, Floor 1 Kom 4, Moscow 119602, Russia; Tax ID No. 7715712231 (Russia); Registration Number 1087746971135 (Russia) [RUSSIA-EO14024] (Linked To: SOVCOMBANK OPEN JOINT STOCK COMPANY).

JOINT STOCK COMMERCIAL BANK NOVIKOMBANK (Cyrillic: АКЦИОНЕРНЫЙ КОММЕРЧЕСКИЙ БАНК НОВИКОМБАНК АКЦИОНЕРНОЕ ОБЩЕСТВО) (a.k.a. AKTSIONERNY KOMMERCHESKI BANK NOVIKOMBANK AKTSIONERNOE OBSHCHESTVO; a.k.a. AO AKB NOVIKOMBANK (Cyrillic: АО АКБ НОВИКОМБАНК); a.k.a. JOINT STOCK COMMERCIAL BANK NOVIKOMBANK JOINT STOCK COMPANY; f.k.a. NOVIKOMBANK AO; a.k.a. NOVIKOMBANK JCSB), bld.1,Polyanka Bolshaya str. 50/1, Moscow 119180, Russia (Cyrillic: ул. Полянка Большая, д. 50/1, стр. 1, Москва 119180, Russia); SWIFT/BIC CNOVRUMM; Website http://www.novikom.ru; BIK (RU) 044583162; Executive Order 13662 Directive Determination - Subject to Directive 3; Organization Established Date 1993; Registration ID 1027739075891; Tax ID No. 7706196340; Government Gazette Number 17541272; All offices worldwide. For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives [UKRAINE-EO13662] [RUSSIA-EO14024] (Linked To: ROSTEC).

JOINT STOCK COMPANY SAROVBUSINESSBANK (f.k.a. JOINT STOCK COMMERCIAL BANK SAROVBUSINESSBANK; a.k.a. JSC SAROVBUSINESSBANK; f.k.a. PUBLIC JOINT STOCK COMPANY SAROVBUSINESSBANK), ul Silkina 13, Sarov, Nizhegorodskaya Oblast 607189, Russia; SWIFT/BIC SARORU2S; Website http://www.sbbank.ru; BIK (RU) 042202718; Target Type Financial Institution [RUSSIA-EO14024] (Linked To: VTB BANK PUBLIC JOINT STOCK COMPANY).

JOINT STOCK COMPANY SOVCOMBANK LIFE (a.k.a. JSC SOVCOMBANK LIFE; a.k.a. SOVCOMBANK LIFE JSC), Ul. Butyrskaya, D. 76, P. 1, Moscow 127015, Russia; Website sovcomlife.ru; Tax ID No. 7730058711 (Russia); Registration Number 1027739059754 (Russia) [RUSSIA-EO14024] (Linked To: SOVCOMBANK OPEN JOINT STOCK COMPANY).

LIMITED LIABILITY COMPANY ATLANT S (Cyrillic: ОБЩЕСТВО С ОГРАНИЧЕННОЙ ОТВЕТСТВЕННОСТЬЮ АТЛАНТ С) (a.k.a. ATLANT S LIMITED; a.k.a. ATLANT S OOO; a.k.a. LLC ATLANT S (Cyrillic: ООО АТЛАНТ С)), et 1 pom 1 kom 17, dom 20, ulitsa Pleshcheyeva, Moscow 127560, Russia; Organization Established Date 16 Mar 1992; Tax ID No. 7715023288 (Russia); Registration Number 1027700084312 (Russia) [RUSSIA-EO14024] (Linked To: PUCHKOV, Andrey Sergeyevich).

LIMITED LIABILITY COMPANY INSPIRA INVEST A (Cyrillic: ОБЩЕСТВО С ОГРАНИЧЕННОЙ ОТВЕТСТВЕННОСТЬЮ ИНСПИРА ИНВЕСТ А) (a.k.a. INSPIRA INVEST A OOO; a.k.a. LLC INSPIRA INVEST A (Cyrillic: ООО ИНСПИРА ИНВЕСТ А)), et 1 pom 2 kom 28-1 of 1, dom 9, ulitsa Leninskaya Sloboda, Moscow 115280, Russia; Organization Established Date 10 Apr 2017; Tax ID No. 7725367175 (Russia); Registration Number 1177746359834 (Russia) [RUSSIA-EO14024] (Linked To: PUCHKOV, Andrey Sergeyevich).

LIMITED LIABILITY COMPANY OZON BANK (a.k.a. LLC OZON BANK), 3rd Floor, Olimpiyskiy Prospekt 14, Moscow 129090, Russia; Website bank.ozon.ru; Tax ID No. 7750005771 (Russia); Registration Number 1137711000020 (Russia) [RUSSIA-EO14024] (Linked To: SOVCOMBANK OPEN JOINT STOCK COMPANY).

LIMITED LIABILITY COMPANY VTB DC (a.k.a. LLC VTB DC; a.k.a. VTB DC LIMITED; a.k.a. VTB DC LTD), Room 47, office XIV, 8 Brestskaya Street, Moscow 125047, Russia; d. 35 str. 1, Prospect Leningradski, Moscow 125284, Russia; Executive Order 13662 Directive Determination - Subject to Directive 1; Organization Established Date 2011; Registration Number 5117746058733 (Russia); For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives [UKRAINE-EO13662] [RUSSIA-EO14024] (Linked To: VTB BANK PUBLIC JOINT STOCK COMPANY).

MOBILNYE PLATEZHI LIMITED LIABILITY COMPANY (a.k.a. MOBILNYE PLATEZHI; a.k.a. MOBILNYE PLATEZHI LLC), Pr-Kt Kutuzovskii D. 41, Pom.169, Et.1, Komn.5, Office 4, Moscow 121170, Russia; Website round.ru; Tax ID No. 7730648774 (Russia); Registration Number 1117746605811 (Russia) [RUSSIA-EO14024] (Linked To: SOVCOMBANK OPEN JOINT STOCK COMPANY).

NPF OTKRITIE GROUP (Cyrillic: ГРУППА НПФ ОТКРЫТИЕ) (a.k.a. AKTSIONERNOE OBSHCHESTVO NEGOSUDARSTVENNYI PENSIONNYI FOND OTKRYTIE; a.k.a. AO NPF OTKRYTIE), ul. Timura Frunze, d. 11, str. 13, Moscow 119021, Russia; ul. Gilyarovskogo, d. 39, str. 3, Moscow 129110, Russia; Organization Established Date 09 Jun 2014; Tax ID No. 7704300571 (Russia); Registration Number 1147799009104 (Russia) [RUSSIA-EO14024] (Linked To: PUBLIC JOINT STOCK COMPANY BANK FINANCIAL CORPORATION OTKRITIE).

NPF VTB PENSION FUND JOINT STOCK COMPANY (a.k.a. AKTSIONERNOE OBSHCHESTVO NEGOSUDARSTVENNY PENSIONNY FOND VTB PENSIONNY FOND; f.k.a. NEKOMMERCHESKAYA ORGANIZATSIYA NEGOSUDARSTVENNY PENSIONNY FOND VTB PENSIONNY FOND; a.k.a. NONPROFIT ORGANIZATION NON-STATE PENSION FUND VTB PENSION FUND; a.k.a. NON-STATE PENSION FUND VTB PENSION FUND, JSC; a.k.a. NPF VTB PENSION FUND JSC; a.k.a. NPF VTB PENSIONNY FOND, AO), d. 43 str. 1 ul. Vorontsovskaya, Moscow 109147, Russia; Executive Order 13662 Directive Determination - Subject to Directive 1; Target Type Financial Institution; Registration ID 1147799014692 (Russia); For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives [UKRAINE-EO13662] [RUSSIA-EO14024] (Linked To: VTB BANK PUBLIC JOINT STOCK COMPANY).

OBSHCHESTVO S OGRANICHENNOI OTVETSTVENNOSTYU VTB FOREKS (a.k.a. VTB FOREKS; a.k.a. VTB FOREKS OOO), Nab. Presnenskaya D. 10, Blok S, Floor 16, Moscow 123112, Russia; Organization Established Date 15 Mar 2016; Target Type Financial Institution; Tax ID No. 9701034653 (Russia); Registration Number 1167746257755 (Russia) [RUSSIA-EO14024] (Linked To: VTB BANK PUBLIC JOINT STOCK COMPANY).

OOO NAVIGATOR ASSET MANAGEMENT (Cyrillic: ООО УК НАВИГАТОР) (a.k.a. "ASSET MANAGEMENT COMPANY NAVIGATOR"; a.k.a. "UK NAVIGATOR"), ul. Gilyarovskogo, d. 39, str. 3, et. 12, kom. 17, Moscow 129110, Russia; Organization Established Date 30 Sep 2002; Tax ID No. 7725206241 (Russia); Registration Number 1027725006638 (Russia) [RUSSIA-EO14024] (Linked To: PUBLIC JOINT STOCK COMPANY BANK FINANCIAL CORPORATION OTKRITIE).

OOO OTKRITIE ASSET MANAGEMENT (Cyrillic: ООО УК ОТКРЫТИЕ) (a.k.a. OTKRITIE ASSET MANAGEMENT LTD; a.k.a. UK OTKRYTIE), Ul. Kozhevnicheskaya, d. 14, str. 5, Moscow 115114, Russia; Organization Established Date 08 Dec 2000; Tax ID No. 7705394773 (Russia); Registration Number 1027739072613 (Russia) [RUSSIA-EO14024] (Linked To: PUBLIC JOINT STOCK COMPANY BANK FINANCIAL CORPORATION OTKRITIE).

OOO OTKRITIE CAPITAL (Cyrillic: ООО ОТКРЫТИЕ КАПИТАЛ) (a.k.a. OTKRYTIE KAPITAL), ul. Spartakovskaya, d. 5, str. 1, pom. IX, et mansarda, kom 6A, Moscow 105066, Russia; Organization Established Date 27 Apr 2020; Tax ID No. 9701158264 (Russia); Registration Number 1207700158973 (Russia) [RUSSIA-EO14024] (Linked To: PUBLIC JOINT STOCK COMPANY BANK FINANCIAL CORPORATION OTKRITIE).

OOO OTKRITIE FACTORING (Cyrillic: ООО ОТКРЫТИЕ ФАКТОРИНГ) (a.k.a. OTKRYTIE FAKTORING), Pr-kt Andropova, d. 18, korpus 6, pom. 4-07, Moscow 115432, Russia; ul. Letnikovskaya, d. 10, str. 4, floor 7, pomeshch. I/45, Moscow 115114, Russia; Organization Established Date 21 Apr 2016; Tax ID No. 7725314818 (Russia); Registration Number 1167746399897 (Russia) [RUSSIA-EO14024] (Linked To: PUBLIC JOINT STOCK COMPANY BANK FINANCIAL CORPORATION OTKRITIE).

OOO RGS HOLDING (Cyrillic: ООО РГС ХОЛДИНГ) (a.k.a. RGS KHOLDING), ul. Kievskaya, d. 7, et/kom 2A/2, Moscow 121059, Russia; Organization Established Date 26 Aug 2013; Tax ID No. 7730691642 (Russia); Registration Number 1137746769610 (Russia) [RUSSIA-EO14024] (Linked To: PUBLIC JOINT STOCK COMPANY BANK FINANCIAL CORPORATION OTKRITIE).

OOO TAMOZHENNAYA KARTA (Cyrillic: ООО ТАМОЖЕННАЯ КАРТА) (a.k.a. TAMOZHENNAYA KARTA), proezd Berezovoi Roshchi, dom 12, Moscow 125252, Russia; Per. Plotnikov, d. 19/38, str. 2, Moscow 119002, Russia; Organization Established Date 16 Jun 2000; Tax ID No. 710357343 (Russia); Registration Number 1027739703672 (Russia) [RUSSIA-EO14024] (Linked To: PUBLIC JOINT STOCK COMPANY BANK FINANCIAL CORPORATION OTKRITIE).

OTKRITIE BROKER GROUP (Cyrillic: ГРУППА ОТКРЫТИЕ БРОКЕР) (a.k.a. AKTSIONERNOE OBSHCHESTVO OTKRYTIE BROKER; a.k.a. AO OTKRYTIE BROKER), ul. Letnikovskaya, d. 2, str. 4, Moscow 115114, Russia; Organization Established Date 28 Dec 1995; Tax ID No. 7710170659 (Russia); Registration Number 1027739704772 (Russia) [RUSSIA-EO14024] (Linked To: PUBLIC JOINT STOCK COMPANY BANK FINANCIAL CORPORATION OTKRITIE).

OTKRITIE CAPITAL CYPRUS LIMITED (a.k.a. OTKRITIE CAPITAL LIMITED), Millios Building, flat no: 2, Amathoyntos 42, Limassol 4532, Cyprus; Organization Established Date 06 Sep 2005; Registration Number C165058 (Cyprus) [RUSSIA-EO14024] (Linked To: PUBLIC JOINT STOCK COMPANY BANK FINANCIAL CORPORATION OTKRITIE).

OTKRITIE LTD GROUP (a.k.a. OTKRITIE LTD), Nicolaou Pentadromos Center, flat no: 908G, floor no: 9, Agias Zonis & Thessalonikis 1, Limassol 3025, Cyprus; Organization Established Date 25 Jul 2012; Registration Number C309722 (Cyprus) [RUSSIA-EO14024] (Linked To: PUBLIC JOINT STOCK COMPANY BANK FINANCIAL CORPORATION OTKRITIE).

PAO ROSGOSSTRAKH BANK (Cyrillic: ПАО РОСГОССТРАХ БАНК) (a.k.a. OPEN JOINT-STOCK COMPANY ROSGOSSTRAKH BANK; f.k.a. "RUSS-BANK"), Stroenie 2, 43 Myasnickaya ul., Moscow 107078, Russia; SWIFT/BIC RUIDRUMM; Website www.rgsbank.ru; Tax ID No. 7718105676 (Russia); Registration Number 1027739004809 (Russia) [RUSSIA-EO14024] (Linked To: PUBLIC JOINT STOCK COMPANY BANK FINANCIAL CORPORATION OTKRITIE).

PUBLIC JOINT STOCK COMPANY BANK FINANCIAL CORPORATION OTKRITIE (Cyrillic: ПУБЛИЧНОЕ АКЦИОНЕРНОЕ ОБЩЕСТВО БАНК ФИНАНСОВАЯ КОРПОРАЦИЯ ОТКРЫТИЕ) (a.k.a. OTKRITIE BANK; a.k.a. PAO BANK OTKRITIE FINANCIAL CORPORATION; a.k.a. PJSC BANK FK OTKRITIE (Cyrillic: ПАО БАНК ФК ОТКРЫТИЕ); a.k.a. PUBLIC JOINT STOCK COMPANY BANK OTKRITIE FINANCIAL CORPORATION), d. 2, str. 4, ul. Letnikovskaya, Moscow 115114, Russia; SWIFT/BIC JSNMRUMM; Website http://www.open.ru; Organization Established Date 15 Dec 1992; Tax ID No. 7706092528 (Russia); Registration Number 1027739019208 (Russia) [RUSSIA-EO14024].

PUBLIC JOINT STOCK COMPANY INSURANCE COMPANY ROSGOSSTRAKH (Cyrillic: ПУБЛИЧНОЕ АКЦИОНЕРНОЕ ОБЩЕСТВО СТРАХОВАЯ КОМПАНИЯ РОСГОССТРАХ) (a.k.a. IC ROSGOSSTRAKH PJSC; a.k.a. PJSC IC ROSGOSSTRAKH (Cyrillic: ПАО СК РОСГОССТРАХ); a.k.a. ROSGOSSTRAKH INSURANCE COMPANY GROUP), dom 3, ulitsa Parkovaya, Lyubertsy, Moscow Oblast 140002, Russia; Tax ID No. 7707067683 (Russia); Registration Number 1027739049689 (Russia) [RUSSIA-EO14024] (Linked To: PUBLIC JOINT STOCK COMPANY BANK FINANCIAL CORPORATION OTKRITIE).

PUBLIC JOINT STOCK COMPANY KB VOSTOCHNY (a.k.a. PJSC KB VOSTOCHNY; a.k.a. VOSTOCHNY COMMERCIAL BANK PJSC), Blagoveshchensk, St. Innokentiy Lane 1, Amur 675004, Russia; SWIFT/BIC DALVRU8X; Website vostobank.ru; Tax ID No. 2801015394 (Russia); Registration Number 1022800000112 (Russia) [RUSSIA-EO14024] (Linked To: SOVCOMBANK OPEN JOINT STOCK COMPANY).

RUSKONSALT (a.k.a. RUSKONSALT OOO), Ul. Malaya Semenovskaya D. 15/17, Korpus 4, Kabinet 5 (6 Floor), Moscow 107023, Russia; Website rusconsult.ru; Tax ID No. 7707327194 (Russia); Registration Number 1037707026940 (Russia) [RUSSIA-EO14024] (Linked To: SOVCOMBANK OPEN JOINT STOCK COMPANY).

SEPTEM CAPITAL LIMITED LIABILITY COMPANY (a.k.a. INVESTITSIONNAYA KOMPANIYA SEPTEM; a.k.a. SEPTEM CAPITAL LLC), Ul. Odesskaya D. 2, Pom. 6, Moscow 117638, Russia; Website septemcapital.ru; Tax ID No. 7703809863 (Russia); Registration Number 1147746436749 (Russia) [RUSSIA-EO14024] (Linked To: SOVCOMBANK OPEN JOINT STOCK COMPANY).

SOLLERS-FINANCE LIMITED LIABILITY COMPANY (a.k.a. SOLLERS-FINANCE LLC; a.k.a. SOVCOMBANK LEASING LLC), Ul. Vavilova D. 24, Str. 1, Moscow 119334, Russia; Website sovcombank-leasing.ru; Tax ID No. 7709780434 (Russia); Registration Number 1087746253781 (Russia) [RUSSIA-EO14024] (Linked To: SOVCOMBANK OPEN JOINT STOCK COMPANY).

SOVCOMBANK ASSET MANAGEMENT LIMITED LIABILITY COMPANY (a.k.a. SOVCOMBANK ASSET MANAGEMENT LLC; f.k.a. VOSTOCHNY CAPITAL MANAGEMENT COMPANY LLC), Pl. Suvorovskaya D. 1/52, K. 1, Floor 5, Pomeshch. 522-1, Moscow 127473, Russia; Website www.vostochniy-capital.ru; Tax ID No. 7707404272 (Russia); Registration Number 1187746039392 (Russia) [RUSSIA-EO14024] (Linked To: SOVCOMBANK OPEN JOINT STOCK COMPANY).

SOVCOMBANK FACTORING LIMITED LIABILITY COMPANY, Ul. Kozhevnicheskaya D.14, Moscow 115114, Russia; Website factoring.ru; Tax ID No. 7725625041 (Russia); Registration Number 1077764078226 (Russia) [RUSSIA-EO14024] (Linked To: SOVCOMBANK OPEN JOINT STOCK COMPANY).

SOVCOMBANK OPEN JOINT STOCK COMPANY (a.k.a. SOVCOMBANK OJSC), 46 Prospekt Tekstilshchikov, Kostroma 156000, Russia; SWIFT/BIC SOMRRUM1KST; Website sovcombank.ru; Tax ID No. 4401116480 (Russia) [RUSSIA-EO14024].

SOVCOMBANK SECURITIES LIMITED (f.k.a. KOMANA HOLDINGS LLC), Chapo Central, Flat No: 1, Floor No: 1, Spyrou Kyprianoy 20, Nicosia 1075, Cyprus; Registration Number C339207 (Cyprus) [RUSSIA-EO14024] (Linked To: SOVCOMBANK OPEN JOINT STOCK COMPANY).

SOVCOMBANK TECHNOLOGIES LIMITED LIABILITY COMPANY, Ul. Vokzalnaya D. 3b, Pomeshch. 49, Kom. 307, Odintsovo 143007, Russia; Tax ID No. 4400001172 (Russia); Registration Number 1214400000760 (Russia) [RUSSIA-EO14024] (Linked To: SOVCOMBANK OPEN JOINT STOCK COMPANY).

SOVCOMCARD LIMITED LIABILITY COMPANY (a.k.a. SOVCOMCARD LLC; a.k.a. SOVKOMKARD), Pr-Kt Tekstilshchikov D. 46, Pomeshch. 1, Kom.56, Kostroma 156000, Russia; Tax ID No. 9717049581 (Russia); Registration Number 5167746420265 (Russia) [RUSSIA-EO14024] (Linked To: SOVCOMBANK OPEN JOINT STOCK COMPANY).

SOVKOM FAKTORING (a.k.a. SOVCOM FACTORING), Ul. Vavilova D. 24, Et/Pom/Kom 6/XIX/13, Moscow 119334, Russia; Website roseurofactoring.ru; Tax ID No. 7736654990 (Russia); Registration Number 1137746071077 (Russia) [RUSSIA-EO14024] (Linked To: SOVCOMBANK OPEN JOINT STOCK COMPANY).

SOVKOM LIZING, Ul Vavilova D 24, Moscow 119991, Russia; Tax ID No. 7716228873 (Russia); Registration Number 1037716009011 (Russia) [RUSSIA-EO14024] (Linked To: SOVCOMBANK OPEN JOINT STOCK COMPANY).

TSIFROVYE TEKHNOLOGII BUDUSHCHEGO LIMITED LIABILITY COMPANY (a.k.a. TSIFROVYE TEKHNOLOGII BUDUSCHEGO LLC; a.k.a. TSIFROVYE TEKHNOLOGII BUDUSHCHEGO), Pr-Kt Tekstilshchikov D. 46, Pomeshch. 1, Kom.56, Kostroma 119991, Russia; Website dbosaas.ru; Tax ID No. 7717788370 (Russia); Registration Number 1147746768267 (Russia) [RUSSIA-EO14024] (Linked To: SOVCOMBANK OPEN JOINT STOCK COMPANY).

USM LIMITED LIABILITY COMPANY (a.k.a. YUESEM; a.k.a. "USM LLC"), Pr-Kt Tekstilshchikov D. 46, Pom.1, Kom.56, Kostroma 156000, Russia; Tax ID No. 7725327133 (Russia); Registration Number 1167746761302 (Russia) [RUSSIA-EO14024] (Linked To: SOVCOMBANK OPEN JOINT STOCK COMPANY).

VIETNAM-RUSSIA JOINT VENTURE BANK (a.k.a. NGAN HANG LIEN DOANH VIET- NGA), No.1 Yet Kieu str., Hoan Kiem District, Hanoi, Vietnam; Floor 1, 2nd Floor, No 1, Yet Kieu Street,, Tran Hung Dao Ward, Hoan Kiem District, Hanoi, Vietnam; SWIFT/BIC VRBAVNVX; Website vrbank.com.vn/en; Target Type Financial Institution; Registration Number 0102100878 (Vietnam) [RUSSIA-EO14024] (Linked To: VTB BANK PUBLIC JOINT STOCK COMPANY).

VTB BANK ARMENIA CLOSED JOINT STOCK COMPANY (f.k.a. SAVINGS BANK OF THE REPUBLIC OF ARMENIA; a.k.a. VTB BANK ARMENIA CJSC), 46 Ul, Nalbandyan, Yerevan 375010, Armenia; SWIFT/BIC ARMJAM22; Website www.vtb.am; Executive Order 13662 Directive Determination - Subject to Directive 1; Target Type Financial Institution; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives [UKRAINE-EO13662] [RUSSIA-EO14024] (Linked To: VTB BANK PUBLIC JOINT STOCK COMPANY).

VTB BANK AZERBAIJAN OPEN JOINT STOCK COMPANY (a.k.a. BANK VTB AZERBAIJAN OJSC; a.k.a. JSC VTB BANK AZERBAIJAN; f.k.a. OJSC AF BANK), 38 Khatai ave. Nasimi district, Baku AZ 1008, Azerbaijan; 60, Samed Vurgun str, Baku 1022, Azerbaijan; SWIFT/BIC VTBAAZ22; Website http://en.vtb.az/; Executive Order 13662 Directive Determination - Subject to Directive 1; Target Type Financial Institution; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives [UKRAINE-EO13662] [RUSSIA-EO14024] (Linked To: VTB BANK PUBLIC JOINT STOCK COMPANY).

VTB BANK BELARUS CLOSED JOINT STOCK COMPANY (f.k.a. CJSC SLAVNEFTEBANK; a.k.a. CJSC VTB BANK BELARUS; a.k.a. VTB BANK BELARUS; a.k.a. VTB BANK BELARUS CJSC; a.k.a. VTB BANK BELARUS CLOSED JOINT STOCK COMPANY), 14, Moskovskaya Street, Minsk 220007, Belarus; SWIFT/BIC SLANBY22; Website www.vtb-bank.by; Executive Order 13662 Directive Determination - Subject to Directive 1; Target Type Financial Institution; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives [UKRAINE-EO13662] [RUSSIA-EO14024] (Linked To: VTB BANK PUBLIC JOINT STOCK COMPANY).

VTB BANK EUROPE SE (f.k.a. OST-WEST HANDELSBANK AG; f.k.a. VTB BANK DEUTSCHLAND AG), Ruesterstrasse 7-9, Frankfurt am Main 60325, Germany; SWIFT/BIC DOBADEF1; Website http://www.vtb.eu; Target Type Financial Institution [RUSSIA-EO14024] (Linked To: VTB BANK PUBLIC JOINT STOCK COMPANY).

VTB BANK GEORGIA JOINT STOCK COMPANY (a.k.a. JSC VTB BANK GEORGIA; a.k.a. VTB BANK GEORGIA JSC; f.k.a. "UNITED GEORGIAN BANK"), 14, G. Chanturia Street, Tbilisi 0114, Georgia; SWIFT/BIC UGEBGE22; Website www.vtb.com.ge; Executive Order 13662 Directive Determination - Subject to Directive 1; Target Type Financial Institution; For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives [UKRAINE-EO13662] [RUSSIA-EO14024] (Linked To: VTB BANK PUBLIC JOINT STOCK COMPANY).

VTB BANK PUBLIC JOINT STOCK COMPANY (Cyrillic: БАНК ВТБ ПУБЛИЧНОЕ АКЦИОНЕРНОЕ ОБЩЕСТВО) (f.k.a. BANK FOR FOREIGN TRADE OF RSFSR; f.k.a. BANK OF FOREIGN TRADE OF THE RUSSIAN FEDERATION; f.k.a. BANK VNESHEI TORGOVLI OAO; f.k.a. BANK VNESHNEI TORGOVLI ROSSISKOI FEDERATSII AS A PRIVATE JOINT STOCK COMPANY; f.k.a. BANK VNESHNEI TORGOVLI RSFSR; f.k.a. BANK VNESHNEY TORGOVLI JOINT STOCK COMPANY; f.k.a. BANK VNESHNEY TORGOVLI OPEN JOINT STOCK COMPANY; f.k.a. BANK VNESHNEY TORGOVLI ROSSIYSKOY FEDERATSII CLOSED JOINT STOCK COMPANY; f.k.a. BANK VTB OAO; f.k.a. BANK VTB OPEN JOINT STOCK COMPANY; a.k.a. BANK VTB PAO; a.k.a. BANK VTB PUBLICHNOE AKTSIONERNOE OBSHCHESTVO; f.k.a. CJSC BANK FOR FOREIGN TRADE OF THE RUSSIAN FEDERATION; f.k.a. JSC VTB BANK; f.k.a. OAO BANK VTB; f.k.a. OAO VNESHTORGBANK; f.k.a. OJSC CJSC BANK FOR FOREIGN TRADE; f.k.a. RUSSIAN VNESHTORGBANK; f.k.a. VNESHTORGBANK; f.k.a. VNESHTORGBANK OF RSFSR; f.k.a. VNESHTORGBANK ROSSII CLOSED JOINT STOCK COMPANY; a.k.a. VTB BANK; f.k.a. VTB BANK OAO; f.k.a. VTB BANK OPEN JOINT STOCK COMPANY; a.k.a. VTB BANK PAO; a.k.a. VTB BANK PJSC (Cyrillic: БАНК ВТБ ПАО)), 29, Bolshaya Morskaya str., St. Petersburg 190000, Russia; 37 Plyushchikha ul., Moscow 119121, Russia; 43, Vorontsovskaya str., Moscow 109044, Russia; 11 litera, per. Degtyarny, St. Petersburg 191144, Russia; 11, lit A, Degtyarnyy pereulok, St. Petersburg 191144, Russia; 43, bld.1, Vorontsovskaya str., Moscow 109147, Russia; Bashnya Zapad, Kompleks Federatsiya, 12, nab. Presnenskaya, Moscow 123317, Russia; str. 1, 43, ul. Vorontsovskaya, Moscow 109147, Russia; Vorontsovskaya Str 43, Moscow 109147, Russia; SWIFT/BIC VTBRRUMM; Website www.vtb.com; alt. Website www.vtb.ru; BIK (RU) 044030707; alt. BIK (RU) 044525187; Executive Order 13662 Directive Determination - Subject to Directive 1; Organization Established Date 17 Oct 1990; Target Type Financial Institution; Registration ID 1027739609391 (Russia); Tax ID No. 7702070139 (Russia); Government Gazette Number 00032520 (Russia); License 1000 (Russia); Legal Entity Number 253400V1H6ART1UQ0N98 (Russia); For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] [RUSSIA-EO14024].

VTB CAPITAL HOLDINGS CLOSED JOINT STOCK COMPANY (a.k.a. HOLDING VTB CAPITAL CJSC; a.k.a. KHOLDING VTB KAPITAL ZAKRYTOE AKTSIONERNOE OBSHCHESTVO; a.k.a. VTB CAPITAL HOLDING CJSC; a.k.a. VTB CAPITAL HOLDING ZAO; a.k.a. VTB CAPITAL JSC), 12 Presnenskaya nab., Moscow 123100, Russia; 4th Lesnoy Pereulok 4, Capital Plaza, Moscow 125047, Russia; Room 410, Stolyarniy Pereulok 3, bld 34, Moscow 123022, Russia; Website http://vtbcapital.com; Executive Order 13662 Directive Determination - Subject to Directive 1; Target Type Financial Institution; Registration ID 1097746344596 (Russia); For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives [UKRAINE-EO13662] [RUSSIA-EO14024] (Linked To: VTB BANK PUBLIC JOINT STOCK COMPANY).

VTB FACTORING LTD (a.k.a. OBSHCHESTVO S OGRANICHENNOI OTVETSTVENNOSTYU VTB FAKTORING; a.k.a. VTB FACTORING LIMITED; a.k.a. VTB FAKTORING OOO), d. 52 str. 1 nab.Kosmodamianskaya, Moscow 115054, Russia; Website www.vtbf.ru; Executive Order 13662 Directive Determination - Subject to Directive 1; Target Type Financial Institution; Registration ID 5087746611145 (Russia); For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives [UKRAINE-EO13662] [RUSSIA-EO14024] (Linked To: VTB BANK PUBLIC JOINT STOCK COMPANY).

VTB PENSION ADMINISTRATOR LIMITED (a.k.a. OBSHCHESTVO S OGRANICHENNOI OTVETSTVENNOSTYU VTB PENSIONNY ADMINISTRATOR; a.k.a. VTB PENSION ADMINISTRATOR LTD; a.k.a. VTB PENSIONNY ADMINISTRATOR OOO), d. 52 str. 1 nab.Kosmodamianskaya, Moscow 115054, Russia; Executive Order 13662 Directive Determination - Subject to Directive 1; Organization Type: Activities of holding companies; Registration ID 1097746178232 (Russia); For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives [UKRAINE-EO13662] [RUSSIA-EO14024] (Linked To: VTB BANK PUBLIC JOINT STOCK COMPANY).

VTB REGISTRAR CLOSED JOINT STOCK COMPANY (a.k.a. JOINT STOCK COMPANY VTB REGISTRAR; a.k.a. JSC VTB REGISTRAR; a.k.a. VTB REGISTRAR; a.k.a. VTB REGISTRAR CJSC), 23, Pravdy Street, Moscow 125040, Russia; Website www.vtbreg.ru; BIK (RU) 044525745; Executive Order 13662 Directive Determination - Subject to Directive 1; Registration Number 1045605469744 (Russia); For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives [UKRAINE-EO13662] [RUSSIA-EO14024] (Linked To: VTB BANK PUBLIC JOINT STOCK COMPANY).

VTB SPECIALIZED DEPOSITORY CLOSED JOINT STOCK COMPANY (a.k.a. CJS VTB SPECIALIZED DEPOSITORY; a.k.a. VTB SPECIALIZED DEPOSITORY CJSC), 35 Myasnitskaya Street, Moscow 101000, Russia; Website www.odk.ru; Executive Order 13662 Directive Determination - Subject to Directive 1; Organization Established Date 04 Jul 1996; Target Type Financial Institution; Registration Number 1027739157522 (Russia); For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives [UKRAINE-EO13662] [RUSSIA-EO14024] (Linked To: VTB BANK PUBLIC JOINT STOCK COMPANY).

WEST SIBERIAN COMMERCIAL BANK PUBLIC JOINT STOCK COMPANY (a.k.a. WEST SIBERIAN COMMERCIAL BANK; a.k.a. WEST SIBERIAN COMMERCIAL BANK PJSC; a.k.a. ZAPSIBCOMBANK), 1, 8 March Street, Tyumen, Tyumenskaya Oblast 625000, Russia; Website http://www.zapsibkombank.ru; alt. Website http://www.wscb.ru; BIK (RU) 047102613; Target Type Financial Institution [RUSSIA-EO14024] (Linked To: VTB BANK PUBLIC JOINT STOCK COMPANY).

to its Russia Harmful Foreign Activities sanctions program, and the following persons:

DMITRY, Pantus Aleksandrovich (a.k.a. PANTUS, Dmitriy (Cyrillic: ПАНТУС, Дмитрий); a.k.a. PANTUS, Dzmitry), Minsk, Belarus; DOB 06 Sep 1982; POB Beryozovka, Lida District, Grodno Region, Belarus; nationality Belarus; Gender Male (individual) [BELARUS-EO14038]. 

KHRENIN, Viktor Gennadievich (Cyrillic: ХРЕНИН, Виктор Геннадьевич) (a.k.a. KHRENIN, Victor; a.k.a. KHRENIN, Viktar Genadzevich (Cyrillic: ХРЭНIН, Вiктар Генадзевiч); a.k.a. KHRENIN, Viktar Gienadzjevich; a.k.a. KHRENIN, Viktar Henadzevich (Cyrillic: ХРЭНІН, Віктар Генадзьевіч)), Minsk, Belarus; DOB 01 Aug 1971; POB Novogrudok, Grodno Region, Belarus; nationality Belarus; Gender Male; Passport KH2594621 (Belarus); National ID No. 3010871K003PB1 (Belarus) (individual) [BELARUS-EO14038].

RASSALAI, Viachaslau Yevgenyevich (a.k.a. RASSALAI, Viachaslau; a.k.a. ROSSOLAY, Vyacheslav Evgenyevich (Cyrillic: РОССОЛАЙ, Вячеслав Евгеньевич)), Minsk, Belarus; DOB 17 Oct 1981; POB Minsk, Belarus; nationality Belarus; Gender Male (individual) [BELARUS-EO14038].

RYMASHEUSKI, Aliaksei Ivanavich (Cyrillic: РЫМАШЭЎСКІ, Аляксей Іванавіч) (a.k.a. RIMASHEVSKIY, Aleksey Ivanovich (Cyrillic: РИМАШЕВСКИЙ, Алексей Иванович); a.k.a. RIMASHEVSKIY, Alexey; a.k.a. RIMASHEVSKY, Aleksei), Minsk, Belarus; DOB 29 Jun 1981; POB Salihorsk, Minsk Oblast, Belarus; nationality Belarus; Gender Male; Passport MP2145720 (Belarus); National ID No. 3290681A146PB8 (Belarus) (individual) [BELARUS-EO14038].

SHATROU, Aliaksandr Yauhenavich (Cyrillic: ШАТРОЎ, Аляксандр Яўгенавіч) (a.k.a. SHATROU, Aliaksandr; a.k.a. SHATROU, Alyaksandr; a.k.a. SHATROV, Aleksandr (Cyrillic: ШАТРОВ, Александр); a.k.a. SHATROV, Alexander; a.k.a. SHATROV, Alexander Evgenevich (Cyrillic: ШАТРОВ, Александр Евгеньевич); a.k.a. SHATROV, Alexandr Evgenevich), Belarus; Moscow, Russia; DOB 09 Nov 1978; POB Russia; nationality Belarus; alt. nationality Russia; Gender Male (individual) [BELARUS-EO14038].

VETSIANEVICH, Aliaksandr Piatrovich (Cyrillic: ВЕЦЯНЕВІЧ, Аляксандр Пятровіч) (a.k.a. VETENEVICH, Aleksandr Petrovich (Cyrillic: ВЕТЕНЕВИЧ, Александр Петрович); a.k.a. VETENEVICH, Alexander; a.k.a. VETSIANEVICH, Aliaksandr), Kolesnikova Str. 30, ap. 63, Minsk, Belarus; DOB 20 Jun 1976; nationality Belarus; Gender Male; Passport MC0978411 (Belarus); National ID No. 3200676B070PB8 (Belarus) (individual) [BELARUS-EO14038].

VOLFOVICH, Aleksandr Grigorievich (Cyrillic: ВОЛЬФОВИЧ, Александр Григорьевич), Minsk, Belarus; DOB 28 Jun 1967; POB Kazan, Russia; nationality Belarus; Gender Male (individual) [BELARUS-EO14038].

ZAITSAU, Aliaksandr Mikalaevich (Cyrillic: ЗАЙЦАЎ, Аляксандр Мікалаевіч) (a.k.a. ZAITSEV, Aleksandr Nikolayevich; a.k.a. ZAITSEV, Alexander Nikolaevich (Cyrillic: ЗАЙЦЕВ, Александр Николаевич); a.k.a. ZAYTSEV, Aleksandr; a.k.a. ZAYTSEV, Alexander), Belarus; United Arab Emirates; DOB 22 Nov 1976; POB Ruzhany, Brest Oblast, Belarus; nationality Belarus; Gender Male (individual) [BELARUS-EO14038].

and entities:

BANK DABRABYT JOINT STOCK COMPANY (a.k.a. BANK DABRABYT JSC; f.k.a. BANK MOSCOW-MINSK JOINT STOCK COMPANY; f.k.a. FOREIGN BANK MOSKVA-MINSK; f.k.a. MOSCOW-MINSK FOREIGN BANK; a.k.a. OJSC BANK DABRABYT (Cyrillic: ОАО БАНК ДАБРАБЫТ)), Kommunisticheskaya Str. 49, premises 1, Minsk 220002, Belarus; SWIFT/BIC MMBNBY22; Website www.bankdabrabyt.by; Organization Established Date 07 Apr 2000; Target Type Financial Institution; alt. Target Type State-Owned Enterprise; Registration Number 807000002 (Belarus) [BELARUS-EO14038]. 

BELARUSSIAN BANK OF DEVELOPMENT AND RECONSTRUCTION BELINVESTBANK JOINT STOCK COMPANY (a.k.a. BELARUSSIAN BANK OF DEVELOPMENT AND RECONSTRUCTION JOINT STOCK COMPANY; a.k.a. BELINVESTBANK; a.k.a. BELINVESTBANK JSC), 29 Masherova Av., Minsk 220002, Belarus; SWIFT/BIC BLBBBY2X; Website www.belinvestbank.by; Organization Established Date 09 Jan 2001; Target Type Financial Institution; Registration Number 807000028 (Belarus) [BELARUS-EO14038].

CJSC BELBIZNESLIZING (a.k.a. BELBIZNESLIZING ZAO; a.k.a. BELBUSINESS LEASING), 29 Masherov Ave., office 919, Minsk 220036, Belarus; 11A Korzh Str., Minsk 220036, Belarus; Organization Established Date 27 Apr 1994; Registration Number 100646748 (Belarus) [BELARUS-EO14038] (Linked To: BELARUSSIAN BANK OF DEVELOPMENT AND RECONSTRUCTION BELINVESTBANK JOINT STOCK COMPANY).

INDUSTRIAL-COMMERCIAL PRIVATE UNITARY ENTERPRISE MINOTOR-SERVICE (a.k.a. MINOTOR-SERVICE ENTERPRISE; a.k.a. PROIZVODSTVENNO-TORGOVOYE CHASTNOYE UNITARNOYE PREDPRIYATIYE MINOTOR-SERVIS (Cyrillic: ПРОИЗВОДСТВЕННО-ТОРГОВОЕ ЧАСТНОЕ УНИТАРНОЕ ПРЕДПРИЯТИЕ МИНОТОР-СЕРВИС); a.k.a. UE MINOTOR-SERVICE; a.k.a. UP MINATOR-SERVIS (Cyrillic: УП МIНАТОР-СЭРВIС); a.k.a. UP MINOTOR-SERVIS (Cyrillic: УП МИНОТОР-СЕРВИС); a.k.a. VYTVORCHA-HANDLEVAYE PRYVATNAYE UNITARNAYE PRADPRYEMSTVA MINATOR-SERVIS (Cyrillic: ВЫТВОРЧА-ГАНДЛЕВАЕ ПРЫВАТНАЕ УНIТАРНАЕ ПРАДПРЫЕМСТВА МIНАТОР-СЭРВIС)), ul. Karvata, d. 84, kom. 1, Minsk 220139, Belarus (Cyrillic: ул. Карвата, д. 84, ком. 1, г. Минск 220139, Belarus); Radialnaya str., 40, Minsk 220070, Belarus; Organization Established Date 1991; Registration Number 100665069 (Belarus) [BELARUS-EO14038].

JSC 558 AIRCRAFT REPAIR PLANT (Cyrillic: ОАО 558 АВИАЦИОННЫЙ РЕМОНТНЫЙ ЗАВОД) (a.k.a. JSC 558TH AIRCRAFT REPAIR PLANT; a.k.a. "558 ARZ OAO"; a.k.a. "JSC 558 ARP"), bld. 7, 50 let VLKSM st., Baranovichi, Brest reg. 225415, Belarus (Cyrillic: 7, ул. 50 ВЛКСМ, Барановичи, Брестская обл. 225415, Belarus); Organization Established Date 09 Jun 1992; Registration Number 200166539 (Belarus) [BELARUS-EO14038].

LIMITED LIABILITY COMPANY BELINVEST-ENGINEERING (a.k.a. BELINVEST-ENGINEERING; a.k.a. BELINVEST-INZHINIRING OOO; a.k.a. LLC BELINVEST-ENGINEERING), 2 Melnikaite Str., office 10, Minsk 220004, Belarus; Organization Established Date 01 Jun 2011; Registration Number 191450284 (Belarus) [BELARUS-EO14038] (Linked To: BELARUSSIAN BANK OF DEVELOPMENT AND RECONSTRUCTION BELINVESTBANK JOINT STOCK COMPANY).

LLC 24X7 PANOPTES (Cyrillic: ООО 24X7 ПАНОПТЕС) (a.k.a. 24X7 PANOPTES; a.k.a. OOO 24X7 PANOPTES), Platonova st. 20B-2, Minsk 220005, Belarus (Cyrillic: ул. Платонова, 20Б-2, Минск 220005, Belarus); Registration Number 192603494 (Belarus) [BELARUS-EO14038].

LLC SYNESIS (Cyrillic: ООО СИНЕЗИС) (a.k.a. JSC SYNESIS; a.k.a. SINEZIS OOO), Platonova 20B, Minsk 220005, Belarus; d.20B, pom. 13, komnata 14, ul. Platonova, Minsk, Belarus; Organization Established Date 27 Dec 2007; Registration Number 190950894 (Belarus) [BELARUS-EO14038].

MINSK WHEEL TRACTOR PLANT (Cyrillic: МИНСКИЙ ЗАВОД КОЛЕСНЫХ ТЯГАЧЕЙ) (a.k.a. MINSK WHEEL TRACTOR PLANT JSC; a.k.a. MINSK WHEEL TRACTOR PLANT OPEN JOINT STOCK COMPANY; a.k.a. MINSK WHEELED TRACTOR PLANT; a.k.a. OTKRYTOE AKTSIONERNOE OBSHCHESTVO MINSKII ZAVOD KOLESNYKH TYAGACHEI; a.k.a. "OJSC MWPT"; a.k.a. "OJSC MZKT" (Cyrillic: "ОАО МЗКТ"); a.k.a. "VOLAT"), Partizanski ave 150, 220021, Belarus; Target Type State-Owned Enterprise; Registration Number 100534485 (Belarus) [BELARUS-EO14038].

OJSC KB RADAR-MANAGING COMPANY HOLDING RADAR SYSTEM (Cyrillic: ОАО КБ РАДАР-УПРАВЛЯЮЩАЯ КОМПАНИЯ ХОЛДИНГА СИСТЕМЫ РАДИОЛОКАЦИИ) (a.k.a. JSC KB RADAR; a.k.a. KB RADAR - RADAR AND ELECTRONIC WARFARE SYSTEMS; a.k.a. KB RADAR - RADAR AND EW SYSTEMS; a.k.a. KB RADAR (Cyrillic: КБ РАДАР); a.k.a. KB RADAR OJSC; a.k.a. KB RADAR-UPRAVLYAYUSHCHAYA KOMPANIYA KHOLDINGA SISTEMY RADIOLOKATSII OAO; a.k.a. OPEN JOINT STOCK COMPANY KB RADAR-MANAGEMENT COMPANY HOLDING RADAR SYSTEMS), Partizanskii 64A, Minsk 220026, Belarus (Cyrillic: пр-т Партизанский, 64а, Минск 220026, Belarus); d.24, Nezhiloe pomeshchenie, ul Promyshlennaya, Minsk 220075, Belarus; Organization Established Date 2006; Registration Number 190699027 (Belarus) [BELARUS-EO14038].

OKB TSP SCIENTIFIC PRODUCTION LIMITED LIABILITY COMPANY (Cyrillic: НАУЧНО-ПРОИЗВОДСТВЕННОЕ ОБЩЕСТВО С ОГРАНИЧЕННОЙ ОТВЕТСТВЕННОСТЬЮ ОКБ ТСП) (a.k.a. NAUCHNO-PROIZVODSTVENNOYE OBSCHESTVO S OGRANICHENNOY OTVETSTVENNOSTYU OKB TSP; a.k.a. NAVUKOVA-VYTVORCHAYE TAVARYSTVA S ABMEZHAVANAY ADKAZNASTSYU AKB TSP (Cyrillic: НАВУКОВА-ВЫТВОРЧАЕ ТАВАРЫСТВА З АБМЕЖАВАНАЙ АДКАЗНАСЦЮ АКБ ТСП); a.k.a. NPOOO OKB TSP (Cyrillic: НПООО ОКБ ТСП); a.k.a. NVTAA AKB TSP (Cyrillic: НВТАА АКБ ТСП); f.k.a. OBSCHESTVO S OGRANICHENNOY OTVETSTVENNOSTYU TEKHNOSOYUZPROEKT (Cyrillic: ОБЩЕСТВО С ОГРАНИЧЕННОЙ ОТВЕТСТВЕННОСТЬЮ ТЕХНОСОЮЗПРОЕКТ); a.k.a. OKB TSP SPLLC), Frantsiska Skoriny St., building 1, unit 21, Minsk 220076, Belarus; Organization Established Date 08 Jul 2002; Registration Number 190369982 (Belarus) [BELARUS-EO14038].

OOO OBORONNYE INITSIATIVY (Cyrillic: ООО ОБОРОННЫЕ ИНИЦИАТИВЫ) (a.k.a. LIMITED LIABILITY COMPANY OBORONNYE INITSIATIVY (Cyrillic: ОБЩЕСТВО С ОГРАНИЧЕННОЙ ОТВЕТСТВЕННОСТЬЮ ОБОРОННЫЕ ИНИЦИАТИВЫ; Cyrillic: ТАВАРЫСТВА З АБМЕЖАВАНАЙ АДКАЗНАСЦЮ АБАРОННЫЯ ІНІЦЫЯТЫВЫ); a.k.a. TAA ABARONNYJA INITSYJATYVY (Cyrillic: ТАА АБАРОННЫЯ ІНІЦЫЯТЫВЫ); a.k.a. "DEFENSE INITIATIVES COMPANY"), Perehodnaya str. 64, building 3, office 5, Minsk 220070, Belarus (Cyrillic: ул. Переходная, д. 64 корпус 3, каб. 5, Минск 220070, Belarus); Registration Number 191288292 (Belarus) [BELARUS-EO14038].

OOO SOKHRA (Cyrillic: ООО СОХРА) (a.k.a. OBSCHESTVO S OGRANICHENNOY OTVETSTVENNOSTYU SOKHRA (Cyrillic: ОБЩЕСТВО С ОГРАНИЧЕННОЙ ОТВЕТСТВЕННОСТЬЮ СОХРА); f.k.a. OBSCHESTVO S ORGANICHENNOY OTVETSTVENNOSTYU SOKHRA GRUPP (Cyrillic: ОБЩЕСТВО С ОГРАНИЧЕННОЙ ОТВЕТСТВЕННОСТЬЮ СОХРА ГРУПП); f.k.a. OBSCHESTVO S ORGANICHENNOY OTVETSTVENNOSTYU TIM INDASTRIAL SERVIS KAMPANI (Cyrillic: ОБЩЕСТВО С ОГРАНИЧЕННОЙ ОТВЕТСТВЕННОСТЬЮ ТИМ ИНДАСТРИАЛ СЕРВИС КАМПАНИ); a.k.a. SOHRA LLC; a.k.a. TAA SOKHRA (Cyrillic: ТАА СОХРА); a.k.a. TAVARYSTVA Z ABMEZHAVANAY ADKAZNASTSYU SOKHRA (Cyrillic: ТАВАРЫСТВА З АБМЕЖАВАНАЙ АДКАЗНАСЦЮ СОХРА)), Zavodskaya st., d. 1k, pom. 18, Bolbasovo, Vitebsk Oblast, Orsha District 211004, Belarus (Cyrillic: ул. Заводская, д. 1к, пом. 18, Болбасово, Витебская область, Оршанский район, 211004, Belarus); Revolucyonnaya 17/19, Office no. 22, Minsk 220030, Belarus; Organization Established Date 20 Oct 2014; Registration Number 192363182 (Belarus) [BELARUS-EO14038] (Linked To: ZAITSAU, Aliaksandr Mikalaevich).

PUBLIC JOINT STOCK COMPANY INTEGRAL (Cyrillic: ОТКРЫТОЕ АКЦИОНЕРНОЕ ОБЩЕСТВО ИНТЕГРАЛ) (a.k.a. AAT INTEHRAL - KIRUIUCHAIA KAMPANIIA KHOLDYNGU INTEHRAL (Cyrillic: ААТ ІНТЭГРАЛ - КІРУЮЧАЯ КАМПАНІЯ ХОЛДЫНГУ IНТЭГРАЛ); a.k.a. INTEGRAL-UPRAVLYAYUSHCHAYA KOMPANIYA KHOLDINGA INTEGRAL, OAO; a.k.a. OAO INTEGRAL - MANAGEMENT HOLDING COMPANY INTEGRAL (Cyrillic: ОАО ИНТЕГРАЛ - УПРАВЛЯЮЩАЯ КОМПАНИЯ ХОЛДИНГА ИНТЕГРАЛ); a.k.a. OTKRYTOYE AKTSIONERNOYE OBSCHESTVO INTEGRAL), I.P., d.121A, kom. 327, ul. Kazintsa g., Minsk, Belarus; Registration Number 100386629 (Belarus) [BELARUS-EO14038].

STATE AUTHORITY FOR MILITARY INDUSTRY OF THE REPUBLIC OF BELARUS (a.k.a. BELARUSIAN STATE AUTHORITY FOR MILITARY INDUSTRY; a.k.a. STATE MILITARY-INDUSTRIAL COMMITTEE OF BELARUS (Cyrillic: ГОСУДАРСТВЕННЫЙ ВОЕННО-ПРОМЫШЛЕННЫЙ КОМИТЕТ БЕЛАРУСИ)), 115 Nezavisimost ave, Minsk 220114, Belarus; 115 Nezavisimosti Avenue, Minsk 220114, Belarus; Organization Established Date 30 Dec 2003; Target Type Government Entity [BELARUS-EO14038].

STATE OWNED FOREIGN TRADE UNITARY ENTERPRISE BELSPETSVNESHTECHNIKA (Cyrillic: ГОСУДАРСТВЕННОЕ ВНЕШТОРГОВОЕ УНИТАРНОЕ ПРЕДПРИЯТИЕ БЕЛСПЕЦВНЕШТЕХНИКА) (a.k.a. BELSPETSVNESHTECHNIKA GVTUP (Cyrillic: БЕЛСПЕЦВНЕШТЕХНИКА ГВТУП); a.k.a. SFTUE BELSPETSVNESHTECHNIKA (Cyrillic: ГВТУП БЕЛСПЕЦВНЕШТЕХНИКА)), st. Kalinovskogo, 8, Minsk 220103, Belarus (Cyrillic: ул. Калиновского, д. 8, Минск 220103, Belarus); Organization Established Date 18 Dec 1995; Registration Number 101080981 (Belarus) [BELARUS-EO14038].

VTB CAPITAL HOLDINGS CLOSED JOINT STOCK COMPANY (a.k.a. HOLDING VTB CAPITAL CJSC; a.k.a. KHOLDING VTB KAPITAL ZAKRYTOE AKTSIONERNOE OBSHCHESTVO; a.k.a. VTB CAPITAL HOLDING CJSC; a.k.a. VTB CAPITAL HOLDING ZAO; a.k.a. VTB CAPITAL JSC), 12 Presnenskaya nab., Moscow 123100, Russia; 4th Lesnoy Pereulok 4, Capital Plaza, Moscow 125047, Russia; Room 410, Stolyarniy Pereulok 3, bld 34, Moscow 123022, Russia; Website http://vtbcapital.com; Executive Order 13662 Directive Determination - Subject to Directive 1; Target Type Financial Institution; Registration ID 1097746344596 (Russia); For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives [UKRAINE-EO13662] [RUSSIA-EO14024] (Linked To: VTB BANK PUBLIC JOINT STOCK COMPANY).

VTB FACTORING LTD (a.k.a. OBSHCHESTVO S OGRANICHENNOI OTVETSTVENNOSTYU VTB FAKTORING; a.k.a. VTB FACTORING LIMITED; a.k.a. VTB FAKTORING OOO), d. 52 str. 1 nab.Kosmodamianskaya, Moscow 115054, Russia; Website www.vtbf.ru; Executive Order 13662 Directive Determination - Subject to Directive 1; Target Type Financial Institution; Registration ID 5087746611145 (Russia); For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives [UKRAINE-EO13662] [RUSSIA-EO14024] (Linked To: VTB BANK PUBLIC JOINT STOCK COMPANY).

VTB PENSION ADMINISTRATOR LIMITED (a.k.a. OBSHCHESTVO S OGRANICHENNOI OTVETSTVENNOSTYU VTB PENSIONNY ADMINISTRATOR; a.k.a. VTB PENSION ADMINISTRATOR LTD; a.k.a. VTB PENSIONNY ADMINISTRATOR OOO), d. 52 str. 1 nab.Kosmodamianskaya, Moscow 115054, Russia; Executive Order 13662 Directive Determination - Subject to Directive 1; Organization Type: Activities of holding companies; Registration ID 1097746178232 (Russia); For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives [UKRAINE-EO13662] [RUSSIA-EO14024] (Linked To: VTB BANK PUBLIC JOINT STOCK COMPANY).

VTB REGISTRAR CLOSED JOINT STOCK COMPANY (a.k.a. JOINT STOCK COMPANY VTB REGISTRAR; a.k.a. JSC VTB REGISTRAR; a.k.a. VTB REGISTRAR; a.k.a. VTB REGISTRAR CJSC), 23, Pravdy Street, Moscow 125040, Russia; Website www.vtbreg.ru; BIK (RU) 044525745; Executive Order 13662 Directive Determination - Subject to Directive 1; Registration Number 1045605469744 (Russia); For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives [UKRAINE-EO13662] [RUSSIA-EO14024] (Linked To: VTB BANK PUBLIC JOINT STOCK COMPANY).

VTB SPECIALIZED DEPOSITORY CLOSED JOINT STOCK COMPANY (a.k.a. CJS VTB SPECIALIZED DEPOSITORY; a.k.a. VTB SPECIALIZED DEPOSITORY CJSC), 35 Myasnitskaya Street, Moscow 101000, Russia; Website www.odk.ru; Executive Order 13662 Directive Determination - Subject to Directive 1; Organization Established Date 04 Jul 1996; Target Type Financial Institution; Registration Number 1027739157522 (Russia); For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives [UKRAINE-EO13662] [RUSSIA-EO14024] (Linked To: VTB BANK PUBLIC JOINT STOCK COMPANY).

WEST SIBERIAN COMMERCIAL BANK PUBLIC JOINT STOCK COMPANY (a.k.a. WEST SIBERIAN COMMERCIAL BANK; a.k.a. WEST SIBERIAN COMMERCIAL BANK PJSC; a.k.a. ZAPSIBCOMBANK), 1, 8 March Street, Tyumen, Tyumenskaya Oblast 625000, Russia; Website http://www.zapsibkombank.ru; alt. Website http://www.wscb.ru; BIK (RU) 047102613; Target Type Financial Institution [RUSSIA-EO14024] (Linked To: VTB BANK PUBLIC JOINT STOCK COMPANY).

to its Belarus sanctions program. Additionally, the following existing designation were updated:

IVANOV, Sergei (a.k.a. IVANOV, Sergey); DOB 31 Jan 1953; POB St. Petersburg, Russia; Chief of Staff of the Presidential Executive Office (individual) [UKRAINE-EO13661]. -to- IVANOV, Sergei Borisovich (Cyrillic: ИВАНОВ, Сергей Борисович) (a.k.a. IVANOV, Sergei), Moscow, Russia; DOB 31 Jan 1953; POB St. Petersburg, Russia; nationality Russia; Gender Male (individual) [UKRAINE-EO13661] [RUSSIA-EO14024]. 

JSC TRANSAVIAEXPORT AIRLINES (a.k.a. AAT AVIAKAMPANIIA TRANSAVIIAEKSPART (Cyrillic: ААТ АВIЯКАМПАНIЯ ТРАНСАВIЯЭКСПАРТ); a.k.a. ADKRYTAE AKTSYIANERNAE TAVARYSTVA AVIIAKAMPANIIA TRANSAVIIAEKSPART (Cyrillic: АДКРЫТАЕ АКЦЫЯНЕРНАЕ ТАВАРЫСТВА АВIЯКАМПАНIЯ ТРАНСАВIЯЭКСПАРТ); a.k.a. AVIAKOMPANIYA TRANSAVIAEKSPORT OAO; a.k.a. JOINT STOCK COMPANY TRANSAVIAEXPORT AIRLINES; a.k.a. OAO AVIAKOMPANIYA TRANSAVIAEKSPORT (Cyrillic: ОАО АВИАКОМПАНИЯ ТРАНСАВИАЭКСПОРТ); a.k.a. OTKRYTOYE AKTSIONERNOYE OBSCHESTVO AVIAKOMPANIYA TRANSAVIAEKSPORT; a.k.a. TRANSAVIAEXPORT AIRLINES), 44, Zakharova Str., Minsk 220034, Belarus (Cyrillic: Ул. Захарова, 44, Минск 220034, Belarus); Organization Established Date 28 Dec 1992; Registration Number 100027245 (Belarus) [BELARUS-EO14038]. -to- OTKRYTOYE AKTSIONERNOYE OBSCHESTVO TAE AVIA (Cyrillic: ОТКРЫТОЕ АКЦИОНЕРНОЕ ОБЩЕСТВО ТАЕ АВИА) (f.k.a. AAT AVIAKAMPANIIA TRANSAVIIAEKSPART (Cyrillic: ААТ АВIЯКАМПАНIЯ ТРАНСАВIЯЭКСПАРТ); a.k.a. AAT TAE AVIYA (Cyrillic: ААТ ТАЕ АВIЯ); f.k.a. ADKRYTAE AKTSYIANERNAE TAVARYSTVA AVIIAKAMPANIIA TRANSAVIIAEKSPART (Cyrillic: АДКРЫТАЕ АКЦЫЯНЕРНАЕ ТАВАРЫСТВА АВIЯКАМПАНIЯ ТРАНСАВIЯЭКСПАРТ); a.k.a. ADKRYTAE AKTSYIANERNAE TAVARYSTVA TAE AVIYA (Cyrillic: АДКРЫТАЕ АКЦЫЯНЕРНАЕ ТАВАРЫСТВА ТАЕ АВIЯ); f.k.a. AVIAKOMPANIYA TRANSAVIAEKSPORT OAO; a.k.a. JOINT STOCK COMPANY TRANSAVIAEXPORT AIRLINES; a.k.a. JSC TRANSAVIAEXPORT AIRLINES; f.k.a. OAO AVIAKOMPANIYA TRANSAVIAEKSPORT (Cyrillic: ОАО АВИАКОМПАНИЯ ТРАНСАВИАЭКСПОРТ); a.k.a. OAO TAE AVIA (Cyrillic: ОАО ТАЕ АВИА); f.k.a. OTKRYTOYE AKTSIONERNOYE OBSCHESTVO AVIAKOMPANIYA TRANSAVIAEKSPORT; a.k.a. TRANSAVIAEXPORT AIRLINES), 44, Zakharova Str., Minsk 220034, Belarus (Cyrillic: Ул. Захарова, 44, Минск 220034, Belarus); d. 11, Ul. Pervomayskaya, Minsk 220034, Belarus (Cyrillic: д. 11, ул. Первомайская, Минск 220034, Belarus); Organization Established Date 28 Dec 1992; Registration Number 100027245 (Belarus) [BELARUS-EO14038].

PATRUSHEV, Nikolai Platonovich, Russia; DOB 11 Jul 1951; POB Leningrad, Russian Federation; nationality Russia; Gender Male; Secretary of the Russian Federation Security Council (individual) [UKRAINE-EO13661]. -to- PATRUSHEV, Nikolai Platonovich (Cyrillic: ПАТРУШЕВ, Николай Платонович) (a.k.a. PATRUSHEV, Nikolai), Moscow, Russia; DOB 11 Jul 1951; POB St. Petersburg, Russian Federation; nationality Russia; Gender Male (individual) [UKRAINE-EO13661] [RUSSIA-EO14024].

SECHIN, Igor; DOB 07 Sep 1960; POB St. Petersburg, Russia (individual) [UKRAINE-EO13661]. -to- SECHIN, Igor Ivanovich (Cyrillic: СЕЧИН, Игорь Иванович) (a.k.a. SECHIN, Igor), Moscow, Russia; DOB 07 Sep 1960; POB St. Petersburg, Russia; nationality Russia; Gender Male (individual) [UKRAINE-EO13661] [RUSSIA-EO14024].

On top of that, these entities were added to the Non-SDN Menu-Based Sanctions List (NS-MBS):

CREDIT BANK OF MOSCOW PUBLIC JOINT STOCK COMPANY (a.k.a. CREDIT BANK OF MOSCOW (Cyrillic: МОСКОВСКИЙ КРЕДИТНЫЙ БАНК); a.k.a. CREDIT BANK OF MOSCOW PJSC (Cyrillic: ПАО МОСКОВСКИЙ КРЕДИТНЫЙ БАНК)), Lukov pereulok 2, bldg. 1, Moscow 107045, Russia; SWIFT/BIC MCRBRUMM; Website www.mkb.ru; BIK (RU) 044525659; Organization Established Date 1992; Target Type Financial Institution; Executive Order 14024 Directive Information - For more information on directives, please visit the following link: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions#directives; Executive Order 14024 Directive Information Subject to Directive 3 - All transactions in, provision of financing for, and other dealings in new debt of longer than 14 days maturity or new equity where such new debt or new equity is issued on or after the 'Effective Date (EO 14024 Directive)' associated with this name are prohibited.; Listing Date (EO 14024 Directive 3): 24 Feb 2022; Effective Date (EO 14024 Directive 3): 26 Mar 2022; Registration ID 1027739555282 (Russia); Tax ID No. 7734202860 (Russia) [RUSSIA-EO14024]. 

GAZPROMBANK JOINT STOCK COMPANY (Cyrillic: ГАЗПРОМБАНК АКЦИОНЕРНОЕ ОБЩЕСТВО) (a.k.a. BANK GPB JSC; a.k.a. GAZPROMBANK AO; f.k.a. GAZPROMBANK OPEN JOINT STOCK COMPANY; f.k.a. JOINT STOCK BANK OF THE GAS INDUSTRY GAZPROMBANK), 16 Nametkina Street, Bldg. 1, Moscow 117420, Russia; SWIFT/BIC GAZPRUMM; Website www.gazprombank.ru; Executive Order 13662 Directive Determination - Subject to Directive 1; Organization Established Date 31 Jul 1990; Executive Order 14024 Directive Information - For more information on directives, please visit the following link: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions#directives; Executive Order 14024 Directive Information Subject to Directive 3 - All transactions in, provision of financing for, and other dealings in new debt of longer than 14 days maturity or new equity where such new debt or new equity is issued on or after the 'Effective Date (EO 14024 Directive)' associated with this name are prohibited.; Listing Date (EO 14024 Directive 3): 24 Feb 2022; Effective Date (EO 14024 Directive 3): 26 Mar 2022; Tax ID No. 7744001497 (Russia); Government Gazette Number 09807684 (Russia); Registration Number 1027700167110 (Russia); For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] [RUSSIA-EO14024].

JOINT STOCK COMPANY ALFA-BANK (Cyrillic: АКЦИОНЕРНОЕ ОБЩЕСТВО АЛЬФА-БАНК) (a.k.a. ALFA-BANK; a.k.a. AO ALFA-BANK (Cyrillic: АО АЛЬФА-БАНК); a.k.a. JSC ALFA-BANK; f.k.a. OPEN JOINT STOCK COMPANY ALFA-BANK), Kalanchevskaya Street 27, Moscow 107078, Russia (Cyrillic: Ул. Каланчевская, Д.27, Город москва 107078, Russia); 27, Kalanchyovskaya Ul., Moscow 107078, Russia; SWIFT/BIC ALFARUMM; Website alfabank.ru; alt. Website alfabank.com; BIK (RU) 044525593; Organization Established Date 1990; Target Type Financial Institution; Executive Order 14024 Directive Information - For more information on directives, please visit the following link: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions#directives; Executive Order 14024 Directive Information Subject to Directive 3 - All transactions in, provision of financing for, and other dealings in new debt of longer than 14 days maturity or new equity where such new debt or new equity is issued on or after the 'Effective Date (EO 14024 Directive)' associated with this name are prohibited.; Listing Date (EO 14024 Directive 3): 24 Feb 2022; Effective Date (EO 14024 Directive 3): 26 Mar 2022; Tax ID No. 7728168971 (Russia); Registration Number 1027700067328 (Russia) [RUSSIA-EO14024].

JOINT STOCK COMPANY RUSSIAN AGRICULTURAL BANK (a.k.a. ROSSELKHOZBANK; a.k.a. RUSSIAN AGRICULTURAL BANK; a.k.a. RUSSIAN AGRICULTURAL BANK OJSC; a.k.a. RUSSIAN AGRICULTURAL BANK OPEN JOINT STOCK COMPANY; a.k.a. "RUSAG"), 3, Gagarinsky Pereulok, Moscow 119034, Russia; 3 Gagarinsky per., Moscow 119034, Russia; SWIFT/BIC RUAGRUMM; Website http://www.rshb.ru; Executive Order 13662 Directive Determination - Subject to Directive 1; Executive Order 14024 Directive Information - For more information on directives, please visit the following link: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions#directives; Executive Order 14024 Directive Information Subject to Directive 3 - All transactions in, provision of financing for, and other dealings in new debt of longer than 14 days maturity or new equity where such new debt or new equity is issued on or after the 'Effective Date (EO 14024 Directive)' associated with this name are prohibited.; Listing Date (EO 14024 Directive 3): 24 Feb 2022; Effective Date (EO 14024 Directive 3): 26 Mar 2022; Government Gazette Number 52750822 (Russia); Registration Number 1027700342890 (Russia); For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] [RUSSIA-EO14024].

JOINT STOCK COMPANY SOVCOMFLOT (a.k.a. JSC SOVCOMFLOT; a.k.a. PAO SOVCOMFLOT; a.k.a. PUBLICHNOE AKTSIONERNOE OBSCHESTVO SOVREMENNYY KOMMERCHESKIY FLOT), Ul. Gasheka D. 6, Moscow 125047, Russia; Nab. Reki Moiki d.3, Lit. A, Saint Petersburg 191186, Russia; Website sovcomflot.ru; alt. Website www.scf-group.com; Executive Order 14024 Directive Information - For more information on directives, please visit the following link: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions#directives; Executive Order 14024 Directive Information Subject to Directive 3 - All transactions in, provision of financing for, and other dealings in new debt of longer than 14 days maturity or new equity where such new debt or new equity is issued on or after the 'Effective Date (EO 14024 Directive)' associated with this name are prohibited.; Listing Date (EO 14024 Directive 3): 24 Feb 2022; Effective Date (EO 14024 Directive 3): 26 Mar 2022; Tax ID No. 7702060116 (Russia); Registration Number 1027739028712 (Russia) [RUSSIA-EO14024].

OPEN JOINT STOCK COMPANY RUSSIAN RAILWAYS (Cyrillic: ОТРЫТОЕ АКЦИОНЕРНОЕ ОБЩЕСТВО РОССИЙСКИЕ ЖЕЛЕЗНЫЕ ДОРОГИ) (a.k.a. JSC RUSSIAN RAILWAYS (Cyrillic: ОАО РОССИЙСКИЕ ЖЕЛЕЗНЫЕ ДОРОГИ); a.k.a. RUSSIAN RAILWAYS; a.k.a. RUSSIAN RAILWAYS JSC; a.k.a. "JSC RZD"; a.k.a. "RZHD" (Cyrillic: "ОАО РЖД")), Novaya Basmannaya Street, 2, Moscow 107174, Russia (Cyrillic: ул. Новая Басманная.д.2, Москва 107174, Russia); Website www.rzd.ru; Organization Established Date 18 Sep 2003; Target Type Government Entity; Executive Order 14024 Directive Information - For more information on directives, please visit the following link: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions#directives; Executive Order 14024 Directive Information Subject to Directive 3 - All transactions in, provision of financing for, and other dealings in new debt of longer than 14 days maturity or new equity where such new debt or new equity is issued on or after the 'Effective Date (EO 14024 Directive)' associated with this name are prohibited.; Listing Date (EO 14024 Directive 3): 24 Feb 2022; Effective Date (EO 14024 Directive 3): 26 Mar 2022; Tax ID No. 7708503727 (Russia); Legal Entity Number 253400XX5U3XALBF5728 (Russia); Registration Number 1037739877295 (Russia) [RUSSIA-EO14024].

PUBLIC JOINT STOCK COMPANY ALROSA (Cyrillic: АКЦИОНЕРНАЯ КОМПАНИЯ АЛРОСА ПУБЛИЧНОЕ АКЦИОНЕРНОЕ ОБЩЕСТВО) (a.k.a. AK ALROSA PAO (Cyrillic: АК АЛРОСА ПАО); a.k.a. ALROSA GROUP; a.k.a. PJSC ALROSA), 24 Ozerkovskaya Naberezhnaya, Moscow 115184, Russia; 6 ulitsa Lenina, Mirny, Republic of Sakha (Yakutia) 678174, Russia; Executive Order 14024 Directive Information - For more information on directives, please visit the following link: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions#directives; Executive Order 14024 Directive Information Subject to Directive 3 - All transactions in, provision of financing for, and other dealings in new debt of longer than 14 days maturity or new equity where such new debt or new equity is issued on or after the 'Effective Date (EO 14024 Directive)' associated with this name are prohibited.; Listing Date (EO 14024 Directive 3): 24 Feb 2022; Effective Date (EO 14024 Directive 3): 26 Mar 2022; Tax ID No. 1433000147 (Russia); Legal Entity Number 894500DKUWVBYZLLE651 (Russia); Registration Number 1021400967092 (Russia) [RUSSIA-EO14024].

PUBLIC JOINT STOCK COMPANY GAZPROM (a.k.a. GAZPROM; a.k.a. GAZPROM PAO; a.k.a. PJSC GAZPROM), 2/3 Lakhtinsky Avenue, Bldg. 1, St. Petersburg, Russia 197229, Russia; BOX 1255, St. Petersburg 190900, Russia; 156A Moskovsky Avenue, St. Petersburg, Russia; Executive Order 13662 Directive Determination - Subject to Directive 4; Executive Order 14024 Directive Information - For more information on directives, please visit the following link: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions#directives; Executive Order 14024 Directive Information Subject to Directive 3 - All transactions in, provision of financing for, and other dealings in new debt of longer than 14 days maturity or new equity where such new debt or new equity is issued on or after the 'Effective Date (EO 14024 Directive)' associated with this name are prohibited.; Listing Date (EO 14024 Directive 3): 24 Feb 2022; Effective Date (EO 14024 Directive 3): 26 Mar 2022; Tax ID No. 7736050003 (Russia); Government Gazette Number 00040778 (Russia); Registration Number 1027700070518 (Russia); For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] [RUSSIA-EO14024].

PUBLIC JOINT STOCK COMPANY GAZPROM NEFT (a.k.a. GAZPROM NEFT PAO; a.k.a. GAZPROM NEFT PJSC; a.k.a. PUBLICHNOE AKTSIONERNOE OBSHCHESTVO GAZPROM NEFT), 5, Let. A, Galernaya, Saint Petersburg 190000, Russia; d. 3-5 litera A Ch. Pom. 1N kab. 2401, ul. Pochtamtskaya, St. Petersburg 190000, Russia; Executive Order 13662 Directive Determination - Subject to Directive 2; alt. Executive Order 13662 Directive Determination - Subject to Directive 4; Executive Order 14024 Directive Information - For more information on directives, please visit the following link: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions#directives; Executive Order 14024 Directive Information Subject to Directive 3 - All transactions in, provision of financing for, and other dealings in new debt of longer than 14 days maturity or new equity where such new debt or new equity is issued on or after the 'Effective Date (EO 14024 Directive)' associated with this name are prohibited.; Listing Date (EO 14024 Directive 3): 24 Feb 2022; Effective Date (EO 14024 Directive 3): 26 Mar 2022; Tax ID No. 5504036333 (Russia); Government Gazette Number 42045241 (Russia); Registration Number 1025501701686 (Russia); For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] [RUSSIA-EO14024].

PUBLIC JOINT STOCK COMPANY ROSTELECOM (Cyrillic: ПУБЛИЧНОЕ АКЦИОНЕРНОЕ ОБЩЕСТВО РОСТЕЛЕКОМ) (f.k.a. PAO MEZHDUGORODNOI I MEZHDUNARODNOI ELEKTRICHESKOI SVYAZI ROSTELEKOM; a.k.a. PJSC ROSTELECOM (Cyrillic: ПАО РОСТЕЛЕКОМ); a.k.a. PUBLICHNOE AKTSIONERNOE OBSHCHESTVO ROSTELEKOM; a.k.a. PUBLICHNOE AKTSIONERNOY OBSHCHESTVO ROSTELEKOM; a.k.a. ROSTELECOM; a.k.a. ROSTELEKOM PJSC), P.O. Box: 14, 1, Tverskaya-Yamskaya Street, Moscow 125047, Russia; 30 (building 1), Goncharnaya st., Moscow 115172, Russia; d. 14 litera A, naberezhnaya Sinopskaya, St. Petersburg 191167, Russia (Cyrillic: Д. 14, ЛИТЕРА А, НАБ СИНОПСКАЯ, ВН.ТЕР.Г. МУНИЦИПАЛЬНЫЙ ОКРУГ СМОЛЬНИНСКОЕ, Г.Санкт-Петербург 191167, Russia); Organization Established Date 1993; Executive Order 14024 Directive Information - For more information on directives, please visit the following link: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions#directives; Executive Order 14024 Directive Information Subject to Directive 3 - All transactions in, provision of financing for, and other dealings in new debt of longer than 14 days maturity or new equity where such new debt or new equity is issued on or after the 'Effective Date (EO 14024 Directive)' associated with this name are prohibited.; Listing Date (EO 14024 Directive 3): 24 Feb 2022; Effective Date (EO 14024 Directive 3): 26 Mar 2022; Tax ID No. 7707049388 (Russia); Legal Entity Number 2534001D752JPNM0H170 (Russia); Registration Number 1027700198767 (Russia) [RUSSIA-EO14024].

PUBLIC JOINT STOCK COMPANY RUSHYDRO (Cyrillic: ПАО РУСГИДРО) (f.k.a. FEDERAL HYDRO-GENERATING COMPANY RUSHYDRO OAO; a.k.a. FEDERAL HYDRO-GENERATING COMPANY RUSHYDRO PAO; f.k.a. GIDROOGK OAO; f.k.a. OTKRYTOE AKTSIONERNOE OBSCHESTVO FEDERALNAYA GYDROGENERIRUYUSCHAYA KOMPANIYA-RUSGYDRO; a.k.a. PUBLIC JOINT-STOCK COMPANY FEDERAL HYDRO-GENERATING COMPANY - RUSHYDRO (Cyrillic: ПУБЛИЧНОЕ АКЦИОНЕРНОЕ ОБЩЕСТВО ФЕДЕРАЛЬНАЯ ГИДРОГЕНЕРИРУЮЩАЯ КОМПАНИЯ - РУСГИДРО); a.k.a. PUBLICHNOE AKTSIONERNOE OBSCHESTVO FEDERALNAYA GYDROGENERIRUYUSCHAYA KOMPANIYA-RUSGYDRO; a.k.a. PUBLICHNOE AKTSIONERNOE OBSHCHESTVO FEDERALNAYA GIDROGENERIRUYUSHCHAYA KOMPANIYA - RUSGIDRO; a.k.a. RUSGIDRO, PAO), 51, Republic Street, Kedrovyy, Russia; d. 43 k. 1, ul. Dubrovinskogo, Krasnoyarsk, Krasnoyarski Kr. 660017, Russia (Cyrillic: Д. 43, К. 1, УЛ. ДУБРОВИНСКОГО, Г. КРАСНОЯРСК, КРАСНОЯРСКИЙ КРАЙ 660017, Russia); 23 Pravda St, Moscow 127015, Russia; Mail Box No. 54, Moscow 127137, Russia; Organization Established Date 2004; Executive Order 14024 Directive Information - For more information on directives, please visit the following link: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions#directives; Executive Order 14024 Directive Information Subject to Directive 3 - All transactions in, provision of financing for, and other dealings in new debt of longer than 14 days maturity or new equity where such new debt or new equity is issued on or after the 'Effective Date (EO 14024 Directive)' associated with this name are prohibited.; Listing Date (EO 14024 Directive 3): 24 Feb 2022; Effective Date (EO 14024 Directive 3): 26 Mar 2022; Tax ID No. 2460066195 (Russia); Legal Entity Number 2534005TJN9DX4YWVT97 (Russia); Registration Number 1042401810494 (Russia) [RUSSIA-EO14024].

PUBLIC JOINT STOCK COMPANY SBERBANK OF RUSSIA (Cyrillic: ПУБЛИЧНОЕ АКЦИОНЕРНОЕ ОБЩЕСТВО СБЕРБАНК РОССИИ) (f.k.a. JOINT STOCK COMMERCIAL SAVINGS BANK OF THE RUSSIAN FEDERATION; f.k.a. JOINT STOCK COMMERCIAL SAVINGS BANK OF THE RUSSIAN SOVIET FEDERATIVE SOCIALIST REPUBLIC; f.k.a. OJSC SBERBANK OF RUSSIA; f.k.a. OPEN JOINT STOCK COMPANY SBERBANK OF RUSSIA; f.k.a. OTKRYTOE AKTSIONERNOE OBSHCHESTVO SBERBANK ROSSII; a.k.a. PJSC SBERBANK (Cyrillic: ПАО СБЕРБАНК); f.k.a. SBERBANK OF RSFSR; a.k.a. SBERBANK OF RUSSIA; a.k.a. SBERBANK ROSSII; f.k.a. SBERBANK ROSSII OAO), 19 ul. Vavilova, Moscow 117312, Russia (Cyrillic: ул. Вавилова, д. 19, Москва 117312, Russia); SWIFT/BIC SABRRUMM; Website www.sberbank.ru; alt. Website www.sberbank.com; Executive Order 13662 Directive Determination - Subject to Directive 1; Executive Order 14024 Directive Information - For more information on directives, please visit the following link: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions#directives; Executive Order 14024 Directive Information Subject to Directive 3 - All transactions in, provision of financing for, and other dealings in new debt of longer than 14 days maturity or new equity where such new debt or new equity is issued on or after the 'Effective Date (EO 14024 Directive)' associated with this name are prohibited.; Listing Date (EO 14024 Directive 2): 24 Feb 2022; Effective Date (EO 14024 Directive 2): 26 Mar 2022; Listing Date (EO 14024 Directive 3): 24 Feb 2022; Effective Date (EO 14024 Directive 3): 26 Mar 2022; Tax ID No. 7707083893 (Russia); Registration Number 1027700132195 (Russia); For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] [RUSSIA-EO14024].

PUBLIC JOINT STOCK COMPANY TRANSNEFT (Cyrillic: ПУБЛИЧНОЕ АКЦИОНЕРНОЕ ОБЩЕСТВО ТРАНСНЕФТЬ) (f.k.a. AK TRANSNEFT OAO; f.k.a. AKTSIONERNAYA KOMPANIYA PO TRANSPORTU NEFTI TRANSNEFT PAO; a.k.a. JSC TRANSNEFT; a.k.a. OIL TRANSPORTING JOINT STOCK COMPANY TRANSNEFT; a.k.a. PAO TRANSNEFT (Cyrillic: ПАО ТРАНСНЕФТЬ); a.k.a. PJSC TRANSNEFT; a.k.a. PUBLICHNOE AKTSIONERNOE OBSHCHESTVO TRANSNEFT), naberezhnaya Presnenskaya, D. 4, Str. 2, Moscow 123112, Russia (Cyrillic: Наб. Пресненская, Д. 4, СТР. 2, Город Москва 123112, Russia); Website www.transneft.ru; Executive Order 13662 Directive Determination - Subject to Directive 2; Organization Established Date 26 Aug 1993; Executive Order 14024 Directive Information - For more information on directives, please visit the following link: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions#directives; Executive Order 14024 Directive Information Subject to Directive 3 - All transactions in, provision of financing for, and other dealings in new debt of longer than 14 days maturity or new equity where such new debt or new equity is issued on or after the 'Effective Date (EO 14024 Directive)' associated with this name are prohibited.; Listing Date (EO 14024 Directive 3): 24 Feb 2022; Effective Date (EO 14024 Directive 3): 26 Mar 2022; Tax ID No. 7706061801 (Russia); Government Gazette Number 00044463 (Russia); Registration Number 1027700049486 (Russia); For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] [RUSSIA-EO14024].

And the Correspondent Account or Payable-Through Account Sanctions List (CAPTA):

ARIMERO HOLDING LIMITED, Agiou Andreou, 332, Partician Chambers, Limassol 3035, Cyprus; Executive Order 14024 Directive Information - For more information on directives, please visit the following link: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions#directives; Listing Date (EO 14024 Directive 2): 24 Feb 2022; Effective Date (EO 14024 Directive 2): 26 Mar 2022; Registration Number C146742 (Cyprus) [RUSSIA-EO14024] (Linked To: PUBLIC JOINT STOCK COMPANY SBERBANK OF RUSSIA). 

IKS JOINT STOCK COMPANY (a.k.a. AKTSIONERNOE OBSHCHESTVO SPETSIALIZIROVANNYI ZASTROISHCHIK IKS; a.k.a. "AO SZ IKS"; a.k.a. "IKS JSC"), 33 Oktyabrskaya St, Nizhny Novgorod 603005, Russia; Executive Order 14024 Directive Information - For more information on directives, please visit the following link: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions#directives; Listing Date (EO 14024 Directive 2): 24 Feb 2022; Effective Date (EO 14024 Directive 2): 26 Mar 2022; Tax ID No. 5263023906 (Russia); Registration Number 1025203020424 (Russia) [RUSSIA-EO14024] (Linked To: PUBLIC JOINT STOCK COMPANY SBERBANK OF RUSSIA).

INSURANCE COMPANY SBERBANK INSURANCE LIMITED LIABILITY COMPANY (a.k.a. LLC INSURANCE COMPANY SBERBANK INSURANCE; f.k.a. OBSHCHESTVO S OGRANICHENNOI OTVETSTVENNOSTYU STRAKHOVAYA KOMPANIYA SBERBANK OBSHCHEE STRAKHOVANIE; a.k.a. OBSHCHESTVO S OGRANICHENNOI OTVETSTVENNOSTYU STRAKHOVAYA KOMPANIYA SBERBANK STRAKHOVANIE; a.k.a. SBERBANK INSURANCE COMPANY LTD; a.k.a. SBERBANK INSURANCE IC LLC; a.k.a. SBERBANK STRAHOVANIE OOO SK; a.k.a. SK SBERBANK STRAHOVANIE LLC; a.k.a. STRAKHOVAYA KOMPANIYA SBERBANK STRAKHOVANIE), 42 Bolshaya Yakimanka St., b. 1-2, office 209, Moscow 119049, Russia; 7 ul. Pavlovskaya, Moscow, Russia; 3 Poklonnaya Street, building 1, floor 1, office 3, Moscow 121170, Russia; Executive Order 13662 Directive Determination - Subject to Directive 1; Executive Order 14024 Directive Information - For more information on directives, please visit the following link: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions#directives; Listing Date (EO 14024 Directive 2): 24 Feb 2022; Effective Date (EO 14024 Directive 2): 26 Mar 2022; Registration ID 1147746683479 (Russia); Tax ID No. 7706810747 (Russia); For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives [UKRAINE-EO13662] [RUSSIA-EO14024] (Linked To: PUBLIC JOINT STOCK COMPANY SBERBANK OF RUSSIA).

INSURANCE COMPANY SBERBANK LIFE INSURANCE LIMITED LIABILITY COMPANY (a.k.a. LIMITED LIABILITY COMPANY INSURANCE COMPANY SBERBANK INSURANCE; a.k.a. SBERBANK LIFE INSURANCE IC LLC), 3 Poklonnaya St., Building 1, Moscow 121170, Russia; Executive Order 14024 Directive Information - For more information on directives, please visit the following link: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions#directives; Listing Date (EO 14024 Directive 2): 24 Feb 2022; Effective Date (EO 14024 Directive 2): 26 Mar 2022; Tax ID No. 7744002123 (Russia); Registration Number 1037700051146 (Russia) [RUSSIA-EO14024] (Linked To: PUBLIC JOINT STOCK COMPANY SBERBANK OF RUSSIA).

JOINT STOCK COMPANY RASCHETNIYE RESHENIYA (a.k.a. JSC RASCHETNIYE RESHENIYA; a.k.a. LIMITED LIABILITY COMPANY NON-BANK CREDIT ORGANIZATION SETTLEMENT SOLUTIONS; a.k.a. "JSC SETTLEMENT SOLUTIONS"), Room XLIV, 11th floor, 118/1 Varshavskoye Shosse, Moscow 117587, Russia; Executive Order 14024 Directive Information - For more information on directives, please visit the following link: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions#directives; Listing Date (EO 14024 Directive 2): 24 Feb 2022; Effective Date (EO 14024 Directive 2): 26 Mar 2022; Tax ID No. 7727718421 (Russia); Registration Number 1107746390949 (Russia) [RUSSIA-EO14024] (Linked To: PUBLIC JOINT STOCK COMPANY SBERBANK OF RUSSIA).

JOINT STOCK COMPANY SBERBANK (a.k.a. AKTSIONERNE TOVARYSTVO SBERBANK; a.k.a. JSC SBERBANK; a.k.a. JSC SBERBANK OF RUSSIA; a.k.a. PUBLICHNE AKTSIONERNE TOVARYSTVO DOCHIRNII BANK SBERBANKU ROSII; f.k.a. SBERBANK OF RUSSIA SUBSIDIARY BANK PRIVATE JOINT STOCK COMPANY; a.k.a. SBERBANK OF RUSSIA SUBSIDIARY BANK PUBLIC JOINT STOCK COMPANY; a.k.a. SUBSIDIARY BANK SBERBANK OF RUSSIA PUBLIC JOINT STOCK COMPANY), 46 Volodymyrska street, Kyiv 01601, Ukraine; 46 Vladimirskaya St, Kyiv 01601, Ukraine; SWIFT/BIC SABRUAUK; Website www.sberbank.ua; alt. Website sbrf.com.ua; Executive Order 13662 Directive Determination - Subject to Directive 1; Executive Order 14024 Directive Information - For more information on directives, please visit the following link: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions#directives; Listing Date (EO 14024 Directive 2): 24 Feb 2022; Effective Date (EO 14024 Directive 2): 26 Mar 2022; Registration ID 25959784 (Ukraine); Tax ID No. 259597826652 (Ukraine); For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives [UKRAINE-EO13662] [RUSSIA-EO14024] (Linked To: PUBLIC JOINT STOCK COMPANY SBERBANK OF RUSSIA).

JOINT STOCK COMPANY SBERBANK AUTOMATED TRADE SYSTEM (a.k.a. JOINT STOCK COMPANY SBERBANK-AUTOMATED SYSTEM FOR TRADING; a.k.a. JSC SBERBANK-AUTOMATED SYSTEM FOR TRADING; a.k.a. SBERBANK-AST JSC; a.k.a. SBERBANK-AST ZAO; a.k.a. SBERBANK-AUTOMATED TRADING SYSTEM CLOSED JOINT STOCK COMPANY; a.k.a. ZAKRYTOE AKTSIONERNOE OBSHCHESTVO SBERBANK AVTOMATIZIROVANNAYA SISTEMA TORGOV), d. 24 str. 2 ul. Novoslobodskaya, Moscow 127055, Russia; 12 B. Savvinsky Lane, building 9, floor 1, office 1, room 1, Moscow 119435, Russia; Website www.sberbank-ast.ru; Executive Order 13662 Directive Determination - Subject to Directive 1; Executive Order 14024 Directive Information - For more information on directives, please visit the following link: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions#directives; Listing Date (EO 14024 Directive 2): 24 Feb 2022; Effective Date (EO 14024 Directive 2): 26 Mar 2022; Registration ID 1027707000441 (Russia); Tax ID No. 7707308480 (Russia); For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives [UKRAINE-EO13662] [RUSSIA-EO14024] (Linked To: PUBLIC JOINT STOCK COMPANY SBERBANK OF RUSSIA).

JOINT STOCK COMPANY SBERBANK LEASING (a.k.a. CJSC SBERBANK LEASING; f.k.a. RUSSKO-GERMANSKAYA LIZINGOVAYA KOMPANIYA ZAO; a.k.a. SBERBANK LEASING JSC; a.k.a. SBERBANK LEASING ZAO; a.k.a. SBERBANK LIZING ZAKRYTOE AKTSIONERNOE OBSHCHESTVO), Novoivanovskoe workers settlement, Odintsovo, Moscow Region 143026, Russia; 6 Vorobievskoe shosse, Moscow 119285, Russia; Website www.sberleasing.ru; Executive Order 13662 Directive Determination - Subject to Directive 1; Executive Order 14024 Directive Information - For more information on directives, please visit the following link: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions#directives; Listing Date (EO 14024 Directive 2): 24 Feb 2022; Effective Date (EO 14024 Directive 2): 26 Mar 2022; Registration ID 1027739000728 (Russia); Tax ID No. 7707009586 (Russia); For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives [UKRAINE-EO13662] [RUSSIA-EO14024] (Linked To: PUBLIC JOINT STOCK COMPANY SBERBANK OF RUSSIA).

JOINT STOCK COMPANY SBERBANK PRIVATE PENSION FUND (a.k.a. CJSC NON-STATE PENSION FUND OF SBERBANK; f.k.a. NEGOSUDARSTVENNY PENSIONNY FOND SBERBANKA; a.k.a. NPF SBERBANKA ZAO; a.k.a. SBERBANK PPF JSC; a.k.a. SBERBANK PRIVATE PENSION FUND CLOSED JOINT STOCK COMPANY; a.k.a. ZAKRYTOE AKTSIONERNOE OBSHCHESTVO NEGOSUDARSTVENNY PENSIONNY FOND SBERBANKA), d. 31 G ul. Shabolovka, Moscow 115162, Russia; Website www.npfsberbanka.ru; Executive Order 13662 Directive Determination - Subject to Directive 1; Executive Order 14024 Directive Information - For more information on directives, please visit the following link: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions#directives; Listing Date (EO 14024 Directive 2): 24 Feb 2022; Effective Date (EO 14024 Directive 2): 26 Mar 2022; Registration ID 1147799009160 (Russia); Tax ID No. 7725352740 (Russia); For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives [UKRAINE-EO13662] [RUSSIA-EO14024] (Linked To: PUBLIC JOINT STOCK COMPANY SBERBANK OF RUSSIA).

LIMITED LIABILITY COMPANY MARKET FUND ADMINISTRATION (a.k.a. SBERBANK FUND ADMINISTRATION LIMITED LIABILITY COMPANY; a.k.a. "MARKET FA LLC"), 79 V. Lenina St, room 8, Derbent, Dagestan 368602, Russia; Executive Order 14024 Directive Information - For more information on directives, please visit the following link: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions#directives; Listing Date (EO 14024 Directive 2): 24 Feb 2022; Effective Date (EO 14024 Directive 2): 26 Mar 2022; Tax ID No. 7736618039 (Russia); Registration Number 1107746400827 (Russia) [RUSSIA-EO14024] (Linked To: PUBLIC JOINT STOCK COMPANY SBERBANK OF RUSSIA).

LIMITED LIABILITY COMPANY PROMISING INVESTMENTS (a.k.a. "PERSPECTIVE INVESTMENTS LIMITED LIABILITY COMPANY"; a.k.a. "PROMISING INVESTMENTS LLC"), 46 Molodezhnaya St., Office 335, Odintsovo, Moscow Region 143007, Russia; Executive Order 14024 Directive Information - For more information on directives, please visit the following link: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions#directives; Listing Date (EO 14024 Directive 2): 24 Feb 2022; Effective Date (EO 14024 Directive 2): 26 Mar 2022; Tax ID No. 5032218680 (Russia); Registration Number 1105032001458 (Russia) [RUSSIA-EO14024] (Linked To: PUBLIC JOINT STOCK COMPANY SBERBANK OF RUSSIA).

LIMITED LIABILITY COMPANY SBERBANK CAPITAL (a.k.a. OBSHCHESTVO S OGRANICHENNOI OTVETSTVENNOSTYU SBERBANK KAPITAL; a.k.a. SBERBANK CAPITAL LIMITED LIABILITY COMPANY; a.k.a. SBERBANK CAPITAL LLC; a.k.a. SBERBANK KAPITAL OOO), d. 19 ul. Vavilova, Moscow 117997, Russia; Executive Order 13662 Directive Determination - Subject to Directive 1; Executive Order 14024 Directive Information - For more information on directives, please visit the following link: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions#directives; Listing Date (EO 14024 Directive 2): 24 Feb 2022; Effective Date (EO 14024 Directive 2): 26 Mar 2022; Registration ID 1087746887678 (Russia); Tax ID No. 7736581290 (Russia); For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives [UKRAINE-EO13662] [RUSSIA-EO14024] (Linked To: PUBLIC JOINT STOCK COMPANY SBERBANK OF RUSSIA).

LIMITED LIABILITY COMPANY SBERBANK CIB HOLDING (a.k.a. SB KIB KHOLDING; a.k.a. SBERBANK CIB HOLDING LLC), 19 Vavilova St, Moscow 117312, Russia; Executive Order 14024 Directive Information - For more information on directives, please visit the following link: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions#directives; Listing Date (EO 14024 Directive 2): 24 Feb 2022; Effective Date (EO 14024 Directive 2): 26 Mar 2022; Tax ID No. 7709297379 (Russia); Registration Number 1027700057428 (Russia) [RUSSIA-EO14024] (Linked To: PUBLIC JOINT STOCK COMPANY SBERBANK OF RUSSIA).

LIMITED LIABILITY COMPANY SBERBANK FACTORING (a.k.a. KORUS DISTRIBUTION LIMITED; a.k.a. SBERBANK FACTORING LLC; a.k.a. SBERBANK FAKTORING), Room I, 31a/bld. 1 Leningradsky Ave, Moscow 125284, Russia; Executive Order 14024 Directive Information - For more information on directives, please visit the following link: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions#directives; Listing Date (EO 14024 Directive 2): 24 Feb 2022; Effective Date (EO 14024 Directive 2): 26 Mar 2022; Tax ID No. 7802754982 (Russia); Registration Number 1117847260794 (Russia) [RUSSIA-EO14024] (Linked To: PUBLIC JOINT STOCK COMPANY SBERBANK OF RUSSIA).

LIMITED LIABILITY COMPANY SBERBANK FINANCIAL COMPANY (a.k.a. LLC SBERBANK FINANCIAL COMPANY; a.k.a. OBSHCHESTVO S OGRANICHENNOI OTVETSTVENNOSTYU FINANSOVAYA KOMPANIYA SBERBANKA; a.k.a. SBERBANK FINANCE COMPANY LIMITED LIABILITY COMPANY; a.k.a. SBERBANK FINANCE LLC; a.k.a. SBERBANK-FINANCE; a.k.a. SBERBANK-FINANS OOO), d. 29/16 per. Sivtsev Vrazhek, Moscow 119002, Russia; Executive Order 13662 Directive Determination - Subject to Directive 1; Executive Order 14024 Directive Information - For more information on directives, please visit the following link: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions#directives; Listing Date (EO 14024 Directive 2): 24 Feb 2022; Effective Date (EO 14024 Directive 2): 26 Mar 2022; Registration ID 1107746399903 (Russia); Tax ID No. 7736617998 (Russia); For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives [UKRAINE-EO13662] [RUSSIA-EO14024] (Linked To: PUBLIC JOINT STOCK COMPANY SBERBANK OF RUSSIA).

LIMITED LIABILITY COMPANY SBERBANK INSURANCE BROKER (a.k.a. LLC INSURANCE BROKER OF SBERBANK; a.k.a. OBSHCHESTVO S OGRANICHENNOI OTVETSTVENNOSTYU STRAKHOVOI BROKER SBERBANKA; a.k.a. OOO STRAKHOVOI BROKER SBERBANKA; a.k.a. SBERBANK INSURANCE BROKER LLC), 42 Bolshaya Yakimanka St., b. 1-2, office 206, Moscow 119049, Russia; 1 Vasilisy Kozhinoy Street, building 1, floor 11, room 30, Moscow 121096, Russia; Executive Order 13662 Directive Determination - Subject to Directive 1; Executive Order 14024 Directive Information - For more information on directives, please visit the following link: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions#directives; Listing Date (EO 14024 Directive 2): 24 Feb 2022; Effective Date (EO 14024 Directive 2): 26 Mar 2022; Registration ID 1147746683468 (Russia); Tax ID No. 7706810730 (Russia); For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives [UKRAINE-EO13662] [RUSSIA-EO14024] (Linked To: PUBLIC JOINT STOCK COMPANY SBERBANK OF RUSSIA).

LIMITED LIABILITY COMPANY SBERBANK INVESTMENTS (a.k.a. SBERBANK INVESTMENTS LLC; a.k.a. SBERBANK INVESTMENTS OOO), 46 Molodezhnaya St, Odintsovo, Moscow Region 143002, Russia; Executive Order 13662 Directive Determination - Subject to Directive 1; Executive Order 14024 Directive Information - For more information on directives, please visit the following link: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions#directives; Listing Date (EO 14024 Directive 2): 24 Feb 2022; Effective Date (EO 14024 Directive 2): 26 Mar 2022; Tax ID No. 5039441 (Russia); Registration Number 1105032007761 (Russia); For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives [UKRAINE-EO13662] [RUSSIA-EO14024] (Linked To: PUBLIC JOINT STOCK COMPANY SBERBANK OF RUSSIA).

LIMITED LIABILITY COMPANY YOOMONEY (a.k.a. YOOMONEY LIMITED LIABILITY COMPANY; a.k.a. YOOMONEY LLC), 82 bld. 2 Sadovnicheskaya St, Moscow 115035, Russia; Executive Order 14024 Directive Information - For more information on directives, please visit the following link: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions#directives; Listing Date (EO 14024 Directive 2): 24 Feb 2022; Effective Date (EO 14024 Directive 2): 26 Mar 2022; Tax ID No. 7736554890 (Russia); Registration Number 1077746365113 (Russia) [RUSSIA-EO14024] (Linked To: PUBLIC JOINT STOCK COMPANY SBERBANK OF RUSSIA).

OPEN JOINT STOCK COMPANY BPS-SBERBANK (Cyrillic: ОТКРЫТОЕ АКЦИОНЕРНОЕ ОБЩЕСТВО СБЕР БАНК) (a.k.a. BPS SBERBANK OJSC; a.k.a. BPS-SBERBANK OAO (Cyrillic: ОАО СБЕР БАНК); a.k.a. SBER BANK), 6 Mulyavina Boulevard, Minsk 220005, Belarus; SWIFT/BIC BPSBBY2X; Website www.sber-bank.by; alt. Website www.bps-sberbank.by; Executive Order 13662 Directive Determination - Subject to Directive 1; Executive Order 14024 Directive Information - For more information on directives, please visit the following link: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions#directives; Listing Date (EO 14024 Directive 2): 24 Feb 2022; Effective Date (EO 14024 Directive 2): 26 Mar 2022; Tax ID No. 100219673 (Belarus); For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives [UKRAINE-EO13662] [RUSSIA-EO14024] (Linked To: PUBLIC JOINT STOCK COMPANY SBERBANK OF RUSSIA).

PUBLIC JOINT STOCK COMPANY SBERBANK OF RUSSIA (Cyrillic: ПУБЛИЧНОЕ АКЦИОНЕРНОЕ ОБЩЕСТВО СБЕРБАНК РОССИИ) (f.k.a. JOINT STOCK COMMERCIAL SAVINGS BANK OF THE RUSSIAN FEDERATION; f.k.a. JOINT STOCK COMMERCIAL SAVINGS BANK OF THE RUSSIAN SOVIET FEDERATIVE SOCIALIST REPUBLIC; f.k.a. OJSC SBERBANK OF RUSSIA; f.k.a. OPEN JOINT STOCK COMPANY SBERBANK OF RUSSIA; f.k.a. OTKRYTOE AKTSIONERNOE OBSHCHESTVO SBERBANK ROSSII; a.k.a. PJSC SBERBANK (Cyrillic: ПАО СБЕРБАНК); f.k.a. SBERBANK OF RSFSR; a.k.a. SBERBANK OF RUSSIA; a.k.a. SBERBANK ROSSII; f.k.a. SBERBANK ROSSII OAO), 19 ul. Vavilova, Moscow 117312, Russia (Cyrillic: ул. Вавилова, д. 19, Москва 117312, Russia); SWIFT/BIC SABRRUMM; Website www.sberbank.ru; alt. Website www.sberbank.com; Executive Order 13662 Directive Determination - Subject to Directive 1; Executive Order 14024 Directive Information - For more information on directives, please visit the following link: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions#directives; Executive Order 14024 Directive Information Subject to Directive 3 - All transactions in, provision of financing for, and other dealings in new debt of longer than 14 days maturity or new equity where such new debt or new equity is issued on or after the 'Effective Date (EO 14024 Directive)' associated with this name are prohibited.; Listing Date (EO 14024 Directive 2): 24 Feb 2022; Effective Date (EO 14024 Directive 2): 26 Mar 2022; Listing Date (EO 14024 Directive 3): 24 Feb 2022; Effective Date (EO 14024 Directive 3): 26 Mar 2022; Tax ID No. 7707083893 (Russia); Registration Number 1027700132195 (Russia); For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] [RUSSIA-EO14024].

SB SECURITIES SA, Boulevard Konrad Adenauer 2, Luxembourg 1115, Luxembourg; 14, rue Edward Steichen, L-2540, Luxembourg; Executive Order 13662 Directive Determination - Subject to Directive 1; Executive Order 14024 Directive Information - For more information on directives, please visit the following link: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions#directives; Listing Date (EO 14024 Directive 2): 24 Feb 2022; Effective Date (EO 14024 Directive 2): 26 Mar 2022; Registration ID B171037 (Luxembourg); For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives [UKRAINE-EO13662] [RUSSIA-EO14024] (Linked To: PUBLIC JOINT STOCK COMPANY SBERBANK OF RUSSIA).

SBERBANK EUROPE AG, Schwarzenbergplatz 3, Wien 1010, Austria; SWIFT/BIC SABRATWW; Website www.sberbank.at; Executive Order 13662 Directive Determination - Subject to Directive 1; Executive Order 14024 Directive Information - For more information on directives, please visit the following link: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions#directives; Listing Date (EO 14024 Directive 2): 24 Feb 2022; Effective Date (EO 14024 Directive 2): 26 Mar 2022; Tax ID No. ATU55795009 (Austria); Registration Number FN 161285 i (Austria); For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE-EO13662] [RUSSIA-EO14024] (Linked To: PUBLIC JOINT STOCK COMPANY SBERBANK OF RUSSIA).

SETELEM BANK LIMITED LIABILITY COMPANY (Cyrillic: ОБЩЕСТВО С ОГРАНИЧЕННОЙ ОТВЕТСТВЕННОСТЬЮ СЕТЕЛЕМ БАНК) (a.k.a. CETELEM BANK LIMITED LIABILITY COMPANY; a.k.a. CETELEM BANK LLC (Cyrillic: СЕТЕЛЕМ БАНК ООО); f.k.a. KOMMERCHESKI BANK UKRSIBBANK OBSHCHESTVO S OGRANICHENNOI OTVETSTVENNOSTYU; a.k.a. SETELEM BANK OBSHCHESTVO S OGRANICHENNOI OTVETSTVENNOSTYU; a.k.a. SETELEM BANK OOO), 26 ul. Pravdy, Moscow 125124, Russia (Cyrillic: ул. Правды, д. 26, г. Москва 125124, Russia); SWIFT/BIC CETBRUMM; Website www.cetelem.ru; Executive Order 13662 Directive Determination - Subject to Directive 1; Executive Order 14024 Directive Information - For more information on directives, please visit the following link: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions#directives; Listing Date (EO 14024 Directive 2): 24 Feb 2022; Effective Date (EO 14024 Directive 2): 26 Mar 2022; Registration ID 1027739664260 (Russia); Tax ID No. 6452010742 (Russia); For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives [UKRAINE-EO13662] [RUSSIA-EO14024] (Linked To: PUBLIC JOINT STOCK COMPANY SBERBANK OF RUSSIA).

SUBSIDIARY BANK SBERBANK OF RUSSIA JOINT STOCK COMPANY (a.k.a. DOCHERNI BANK AKTSIONERNOE OBSHCHESTVO SBERBANK ROSSII; a.k.a. SB SBERBANK JSC; f.k.a. "TEXAKABANK JSC"), 30/26, Gogol/Kaldayakov Street, Almaty 050010, Kazakhstan; 13/1 Al-Farabi Avenue, Bostandyk District, Almaty 050059, Kazakhstan; Zenkov St, 24, Almaty 480100, Kazakhstan; SWIFT/BIC SABRKZKA; Website www.sberbank.kz; Executive Order 13662 Directive Determination - Subject to Directive 1; Executive Order 14024 Directive Information - For more information on directives, please visit the following link: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions#directives; Listing Date (EO 14024 Directive 2): 24 Feb 2022; Effective Date (EO 14024 Directive 2): 26 Mar 2022; Tax ID No. 600900050984 (Kazakhstan); Registration Number 930740000137 (Kazakhstan); For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives [UKRAINE-EO13662] [RUSSIA-EO14024] (Linked To: PUBLIC JOINT STOCK COMPANY SBERBANK OF RUSSIA).

TEKHNOLOGII KREDITOVANIYA LIMITED LIABILITY COMPANY (a.k.a. OOO LENDING TECHNOLOGIES; a.k.a. OOO TEHNOLOGII KREDITOVANYA), Room 1.104, 23/1 Vavilova St, Moscow 117312, Russia; Executive Order 14024 Directive Information - For more information on directives, please visit the following link: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions#directives; Listing Date (EO 14024 Directive 2): 24 Feb 2022; Effective Date (EO 14024 Directive 2): 26 Mar 2022; Tax ID No. 7736317458 (Russia); Registration Number 1187746782519 (Russia) [RUSSIA-EO14024] (Linked To: PUBLIC JOINT STOCK COMPANY SBERBANK OF RUSSIA).

VYDAYUSHCHIESYA KREDITY MICROCREDIT COMPANY LIMITED LIABILITY COMPANY (a.k.a. MCC VYDAYUSHIESYA KREDITY LLC; a.k.a. MIKROKREDITNAYA KOMPANIYA VYDAYUSHCHIESYA KREDITY), 32 Kutuzovsky Avenue, building 1, floor 6, room 6.С.01, Moscow 121170, Russia; Executive Order 14024 Directive Information - For more information on directives, please visit the following link: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions#directives; Listing Date (EO 14024 Directive 2): 24 Feb 2022; Effective Date (EO 14024 Directive 2): 26 Mar 2022; Tax ID No. 7725374454 (Russia); Registration Number 1177746493473 (Russia) [RUSSIA-EO14024] (Linked To: PUBLIC JOINT STOCK COMPANY SBERBANK OF RUSSIA).

With that, you also get 2 new Russia-related Directives. Directive 2 regards correspondent and payable-through accounts and processing transactions for specified financial institutions:

Pursuant to sections 1(a), 1(d), and 8 of Executive Order 14024, “Blocking Property With Respect To Specified Harmful Foreign Activities of the Government of the Russian Federation” (the “Order”), and following the Secretary of the Treasury’s determination, in consultation with the Secretary of State, under section 1(a)(i) of the Order with respect to the financial services sector of the Russian Federation economy, the Director of the Office of Foreign Assets Control, in consultation with the Department of State, has determined that the following activities by a U.S. financial institution are prohibited, except to the extent provided by law, or unless licensed or otherwise authorized by the Office of Foreign Assets Control:

(1) the opening or maintaining of a correspondent account or payable-through account for or on behalf of foreign financial institutions determined to be subject to the prohibitions of this Directive, or their property or interests in property; and

(2) the processing of a transaction involving foreign financial institutions determined to be subject to the prohibitions of this Directive, or their property or interests in property.

The prohibitions of this Directive apply only with respect to a U.S. financial institution’s opening or maintaining of a correspondent account or payable-through account for or on behalf of, or processing of a transaction involving, a foreign financial institution.

The Director of the Office of Foreign Assets Control, in consultation with the Department of State, has determined that, pursuant to section 1(a)(i) of the Order, the foreign financial institutions listed in Annex 1 to this Directive operate or have operated in the financial services sector of the Russian Federation economy, or are foreign financial institutions that are 50 percent or more owned, directly or indirectly, individually or in the aggregate, by one or more such foreign financial institutions, and are subject to the prohibitions of this Directive.

The prohibitions of this Directive shall take effect: (i) with respect to any foreign financial institution listed in Annex 1, beginning at 12:01 a.m. eastern daylight time on March 26, 2022; or (ii) with respect to a foreign financial institution otherwise determined to be subject to the prohibitions of this Directive, beginning at 12:01 a.m. eastern time on the date that is 30 days after the date of such determination.

Annex I lists what appears to be all the corporate components of Sberbank.

Directive 3 describes new debt and equity restrictions:

Pursuant to sections 1(a), 1(d), and 8 of Executive Order 14024, “Blocking Property With Respect To Specified Harmful Foreign Activities of the Government of the Russian Federation” (the “Order”), the Director of the Office of Foreign Assets Control, in consultation with the Department of State, has determined that the following activities by U.S. persons or within the United States are prohibited, except to the extent provided by law, or unless licensed or otherwise authorized by the Office of Foreign Assets Control:

(1) For new debt or new equity of entities listed in Annex 1, or their property or interests in property, all transactions in, provision of financing for, and other dealings in new debt of longer than 14 days maturity or new equity where such new debt or new equity is issued on or after 12:01 a.m. eastern daylight time on March 26, 2022; and

(2) For new debt or new equity of entities otherwise determined to be subject to the prohibitions of this Directive, or their property or interests in property, all transactions in, provision of financing for, and other dealings in new debt of longer than 14 days maturity or new equity where such new debt or new equity is issued on or after 12:01 a.m. eastern time on the date that is 30 days after the date of such determination.

The Director of the Office of Foreign Assets Control, in consultation with the Department of State, has determined that, pursuant to sections 1(a)(i) and 1(a)(vii) of the Order, the entities listed in Annex 1 to this Directive operate or have operated in the financial services sector of the Russian Federation economy, or are owned or controlled by, or have acted or purported to act for or on behalf of, directly or indirectly, the Government of the Russian Federation, and are subject to the prohibitions of this Directive.

All other activities with entities determined to be subject to the prohibitions of this Directive, or involving their property or interests in property, are permitted, provided that such activities are not otherwise prohibited by law, the Order, or any other sanctions program implemented by the Office of Foreign Assets Control.

And then there are the General Licenses:

  • Russia 5 – Official Business of Int’l Organizations & Entities
  • Russia 6 – Export/Reexport of Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components or Software updates, or COVID-related transactions
  • Russia 7 – Overflights, Emergency Landings, Air Ambulances
  • Russia 8 – Energy Related Banking Transactions
  • Russia 9 – Divestment or Transfer of Debt or Equity to non-US persons
  • Russia 10 – Derivative Contracts
  • Russia 11 – Wind-down with VTB Bank, Sovcombank and Bank Financial Corporation Otkritie, or their 50 Percent Rule entities
  • Russia 12 – Rejection of transactions involving VTB Bank, Sovcombank and Bank Financial Corporation Otkritie, or their 50 Percent Rule entities
  • Belarus 6 – Official US Government Business
  • Belarus 7 – Official Business of Int’l Organizations & Entities

And we have new:

990. May a debit to an account of a person blocked pursuant to Executive Order (E.O.) 14024 be authorized as a transaction that is ordinarily incident and necessary to a licensed transaction?

An authorization for transactions that are ordinarily incident and necessary to a transaction licensed pursuant to E.O. 14024 does not implicitly authorize a debit to a blocked account on the books of a U.S. financial institution.  Debits to an account on the books of a U.S. financial institution of a blocked person are only authorized as transactions ordinarily incident and necessary to a licensed transaction if such license explicitly authorizes such debits.

For example, General Licenses (GLs) 9 and 10  explicitly state that debits to accounts on the books of a U.S. financial institution of the blocked entities listed in the GLs are authorized to the extent ordinarily incident and necessary to effect the specified transactions authorized therein.  By contrast, GLs 3 and 11 do not explicitly authorize debits to accounts on the books of a U.S. financial institution of the blocked entities.
 

Released on 02/24/2022

Russian Harmful Foreign Activities Sanctions

989. Does Russia-related Directive 3 under Executive Order (E.O.) 14024, “Prohibitions Related to New Debt and Equity of Certain Russia-related Entities” (Russia-related Entities Directive) prohibit U.S. persons from engaging in dealings related to debt or equity issued before the relevant sanctions effective date by entities subject to it?

No, so long as the terms of such debt (including the repayment period, the interest rate, and the amount) were contractually agreed to before the relevant sanctions effective date described in the Russia-related Entities Directive  and are not modified on or after the relevant sanctions effective date (FAQ 984).  As stated in FAQ 956, loans, contracts, or other agreements that use London Interbank Offered Rate (LIBOR) as a reference rate that are modified to replace such benchmark reference rate will not be treated as new debt for OFAC sanctions purposes, so long as no other material terms of the loan, contract, or agreement are modified. 

Some entities determined to be subject to the prohibitions of the Russia-related Entities Directive may also be subject to additional prohibitions under other sanctions authorities, such as additional directives under E.O. 14024 or E.O. 13662.  It is important to note that each directive operates independently of the others.  For example, if a transaction involves a person subject to two separate directives, a U.S. person engaging in that transaction must comply with both directives.  
 

Released on 02/24/2022

Russian Harmful Foreign Activities Sanctions

988. Does Russia-related Directive 3 under Executive Order (E.O.) 14024, “Prohibitions Related to New Debt and Equity of Certain Russia-related Entities” (Russia-related Entities Directive) prohibit U.S. persons from engaging in all activities with entities subject to it?

No.  The Russia-related Entities Directive prohibits U.S. persons from engaging in only certain activities related to new debt of longer than 14 days maturity or new equity of the entities listed in Annex 1 to the Russia-related Entities Directive, or of entities otherwise determined to be subject to the prohibitions of the Russia-related Entities Directive, as explained in FAQ 984.  Please see FAQ 985 regarding the applicability of OFAC’s 50 Percent Rule with respect to this directive.

Some entities determined to be subject to the prohibitions of the Russia-related Entities Directive may also be subject to additional prohibitions under other sanctions authorities, such as additional directives under E.O. 14024 or E.O. 13662.  It is important to note that each directive operates independently of the others.  For example, if a transaction involves a person subject to two separate directives, a U.S. person engaging in that transaction must comply with both directives.  
 

Released on 02/24/2022

Russian Harmful Foreign Activities Sanctions

987. If a U.S. person entered into a revolving credit facility or long-term loan agreement for an entity determined to be subject to Russia-related Directive 3 under Executive Order (E.O.) 14024, “Prohibitions Related to New Debt and Equity of Certain Russia-related Entities” (Russia-related Entities Directive) prior to the relevant sanctions effective date described in the Russia-related Entities Directive, what are the restrictions on drawdowns from that facility?  Do all drawdowns and disbursements pursuant to the parent agreement need to carry repayment terms of 14 days or less?

If a U.S. person entered into a long-term credit facility or loan agreement prior to the relevant sanctions effective date described in the Russia-related Entities Directive, drawdowns and disbursements with repayment terms of 14 days or less are permitted.  In addition, drawdowns and disbursements whose repayment terms exceed 14 days are not prohibited if the terms of such drawdowns and disbursements (including the length of the repayment period, the interest rate applied to the drawdown, and the maximum drawdown amount) were contractually agreed to prior to the relevant sanctions effective date and are not modified on or after the relevant sanctions effective date.  U.S. persons may not deal in a drawdown or disbursement initiated on or after the relevant sanctions effective date with a repayment term that is longer than 14 days if the terms of the drawdown or disbursement were negotiated on or after the relevant sanctions effective date.  Such a newly negotiated drawdown or disbursement would constitute a prohibited extension of credit.  

Released on 02/24/2022

Russian Harmful Foreign Activities Sanctions

986. What constitutes debt or equity for purposes of Directive 3 under Executive Order (E.O.) 14024, “Prohibitions Related to New Debt and Equity of Certain Russia-related Entities” (Russia-related Entities Directive)?

The term “debt” includes bonds, loans, extensions of credit, loan guarantees, letters of credit, drafts, bankers acceptances, discount notes or bills, or commercial paper.

The term “equity” includes stocks, share issuances, depositary receipts, or any other evidence of title or ownership.
 

Released on 02/24/2022

Russian Harmful Foreign Activities Sanctions

985. Does the 50 Percent Rule apply to Directive 3 under Executive Order (E.O.) 14024, “Prohibitions Related to New Debt and Equity of Certain Russia-related Entities” (Russia-related Entities Directive)?

Yes.  The prohibitions of the Russia-related Entities Directive apply to any entity listed in Annex 1 to the Russia-related Entities Directive or otherwise determined to be subject to the prohibitions of the Russia-related Entities Directive, or their property or interests in property, which includes entities 50 percent or more owned, directly or indirectly, individually or in the aggregate, by one or more entities determined to be subject to the prohibitions of the Russia-related Entities Directive.

Released on 02/24/2022

984. What does Directive 3 under Executive Order (E.O.) 14024, “Prohibitions Related to New Debt and Equity of Certain Russia-related Entities” (Russia-related Entities Directive) prohibit?

The Russia-related Entities Directive prohibits certain dealings by U.S. persons or within the United States in new debt of longer than 14 days maturity or new equity of Russian entities determined to be subject to the prohibitions of the directive or their property or interests in property.  The prohibitions of the Russia-related Entities Directive are effective beginning on 12:01 a.m. eastern daylight time, March 26, 2022 for entities listed in Annex 1 to the Russia-related Entities Directive, or their property or interests in property.  For entities subsequently determined to be subject to the prohibitions of the Russia-related Entities Directive, the prohibitions are effective 12:01 a.m. eastern time 30 days following such determination.

Specifically, the Russia-related Entities Directive prohibits the following activities by U.S. persons or within the United States: all transactions in, provision of financing for, and other dealings in new debt with a maturity of greater than 14 days or new equity of entities listed in Annex 1 to the Russia-related Entities Directive or otherwise determined to be subject to the prohibitions of the Russia-related Entities Directive, or their property or interests in property, where such debt or equity is issued on or after the relevant sanctions effective date. Please see FAQ 985 regarding the applicability of OFAC’s 50 Percent Rule with respect to this directive.

Entity Type

Entities listed in Annex 1 to the Russia-related Entities Directive, or their property or interests in property

Entities otherwise determined to be subject to the prohibitions of the Russia-related Entities Directive, or their property or interests in property

Relevant Sanctions Effective Date

On or after 12:01 a.m. eastern daylight time on March 26, 2022

On or after 12:01 a.m. eastern time on the date that is 30 days after the date of such determination

These prohibitions apply to all new debt with a maturity of greater than 14 days and new equity irrespective of currency denomination.

In addition, the Russia-related Entities Directive prohibits:  (1) any transaction that evades or avoids, has the purpose of evading or avoiding, causes a violation of, or attempts to violate any of the prohibitions of the Russia-related Entities Directive; and (2) any conspiracy formed to violate any of the prohibitions of the Russia-related Entities Directive. 

Some entities determined to be subject to the prohibitions of the Russia-related Entities Directive may also be subject to prohibitions in other sanctions authorities, such as prohibitions of other directives issued under E.O. 14024, or directives issued under E.O. 13662.  It is important to note that each directive operates independently of the others.  For example, if a transaction involves a person subject to two separate directives, a U.S. person engaging in that transaction must comply with both directives.  

Released on 02/24/2022

983. What actions did the Office of Foreign Assets Control (OFAC) take in February 2022 with respect to new debt or equity restrictions pursuant to Executive Order (E.O.) 14024? 

In February 2022, OFAC issued two directives under E.O. 14024 regarding restrictions related to new debt or equity involving certain Russian Federation or Russia-related entities:

  • On February 22, 2022, OFAC issued Directive 1A under E.O. 14024, “Prohibitions Related to Certain Sovereign Debt of the Russian Federation” (Russia-related Sovereign Debt Directive), replacing and superseding Directive 1 under E.O. 14024 of April 15, 2021, to extend existing sovereign debt prohibitions to cover participation in the secondary market for ruble and non-ruble denominated bonds issued after March 1, 2022 by the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation (see FAQs 888 and 965).
  • On February 24, 2022, OFAC issued Directive 3 under E.O. 14024, “Prohibitions Related to New Debt and Equity of Certain Russia-related Entities” (Russia-related Entities Directive) to prohibit all transactions in, provision of financing for, and other dealings in new debt of longer than 14 days maturity or new equity issued on or after 12:01 a.m. eastern daylight time, March 26, 2022 by the entities listed in Annex 1 to that directive, or their property or interests in property.  These same prohibitions also apply to any entity subsequently determined to be subject to the prohibitions of the Russia-related Entities Directive, or its property or interests in property, beginning on or after 12:01 a.m. eastern time on the date that is 30 days after the date of such determination (see FAQ 984).

Entities determined to be subject to the prohibitions of these directives will be listed on the Non-SDN Menu-Based Sanctions List (NS-MBS List) (in addition to any other applicable sanctions lists maintained by OFAC).  Please see FAQ 985 regarding the applicability of OFAC’s 50 Percent Rule with respect to the Russia-related Entities Directive.  Listings on the NS-MBS List will denote when an entity has been determined to be subject to prohibitions, as well as when the prohibitions come into effect with respect to each entity.
 

Released on 02/24/2022

Russian Harmful Foreign Activities Sanctions

982. Are U.S. funds allowed to buy or sell debt or equity of blocked Russian financial institutions?  Are U.S. investors allowed to invest in a fund that holds debt or equity of a blocked Russian financial institution?

Except as authorized under General License (GL) 9 (see FAQ 981), U.S. persons may not buy or sell debt or equity of the Russian financial institutions blocked in February 2022 pursuant to Executive Order (E.O.) 14024.  Accordingly, a U.S. fund may not buy, sell, or otherwise engage in transactions related to debt or equity of the blocked Russian financial institutions and must block such holdings, unless authorized under GL 9 or otherwise authorized by the Office of Foreign Assets Control (OFAC) or exempt.  However, a U.S. fund that contains such blocked holdings generally is not itself considered a blocked entity as long as the blocked holdings represent less than a predominant share by value of debt or equity of blocked persons.  As a result, U.S. persons may continue to invest in the fund and the fund may continue to operate.  The fund may divest itself of blocked holdings as authorized under GL 9 or separately authorized by OFAC.

Released on 02/24/2022

Russian Harmful Foreign Activities Sanctions

981. What does General License (GL) 9 authorize with respect to the debt and equity of certain Russian financial institutions sanctioned pursuant to Executive Order (E.O.) 14024?  What are the implications for U.S. and non-U.S. persons? 

General License (GL) 9 authorizes U.S. persons, until 12:01 a.m. eastern daylight time May 25, 2022, to engage in transactions prohibited by E.O. 14024 that are ordinarily incident and necessary to dealings in debt or equity issued prior to February 24, 2022 of one or more of the following entities (“covered debt or equity”), provided that any divestment or transfer of, or facilitation of divestment or transfer of, covered debt or equity must be to a non-U.S. person:

  • State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank (VEB);
  • 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; and
  • Any entity owned 50 percent or more, directly or indirectly, individually or in the aggregate, by one of the above entities.

This authorization includes the facilitation, clearing, and settling of transactions ordinarily incident and necessary to divest covered debt or equity to a non-U.S. person, including on behalf of U.S. persons.  Also, as part of a divestment transaction to a non-U.S. person, U.S. persons may engage in purchases of or investment in covered debt or equity if ordinarily incident and necessary to buy to cover a short position in such holdings.

To allow the closing of trades initiated before February 24, 2022, paragraph (b) of GL 9 authorizes all transactions that are ordinarily incident and necessary to facilitating, clearing, and settling trades of covered debt or equity through 12:01 a.m. eastern daylight time May 25, 2022, provided such trades were placed prior to 4:00 p.m. eastern standard time on February 24, 2022, including debits to accounts on the books of U.S. financial institutions of certain blocked entities.  

GL 9 does not authorize any transactions involving any persons blocked pursuant to E.O. 14024 other than the entities specified in the GL.  U.S. persons may not sell, or facilitate the sale of, covered debt or equity to blocked persons per the terms of GL 9.  In addition, GL 9 does not authorize U.S. persons to purchase or invest in covered debt or equity other than if necessary to buy to cover, as described above.  GL 9 authorizes transactions in debt or equity issued prior to February 24, 2022 and, thus, does not authorize against prohibitions on new debt or equity, such as those in Directive 3 under E.O. 14024, “Prohibitions Related to New Debt and Equity of Certain Russia-related Entities” (Russia-related Entities Directive).  Please see GL 10 with respect to authorizations related to certain derivative contracts. 

For purposes of assessing whether certain transactions are authorized under GL 9or GL 10, U.S. persons—including financial institutions, registered broker-dealers in securities, securities exchanges, and other market intermediaries and participants—may rely upon the information available to them in the ordinary course of business, including reasonable reliance on information about the underlying transaction provided by the parties thereto.  
 

Released on 02/24/2022

Russian Harmful Foreign Activities Sanctions

980. Do non-U.S. persons risk being sanctioned for engaging in activity with persons sanctioned pursuant to Executive Order (E.O.) 14024? 

OFAC evaluates a range of factors when developing sanctions targets, consistent with foreign policy and national security goals.  In the context of blocking sanctions, non-U.S. persons may be exposed to sanctions risk in relation to activities with persons subject to blocking sanctions pursuant to E.O. 14024.  Under E.O. 14024, non-U.S. persons may be designated if they have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, certain activities, a person whose property and interests in property are blocked pursuant to E.O. 14024, or (in certain circumstances) a blocked government.  Please see sections 1(a)(vi) and 1(b) of E.O. 14024. 

Non-U.S. persons generally do not risk exposure to U.S. blocking sanctions under E.O. 14024 for engaging in transactions with persons subject to the prohibitions of the directives under E.O. 14024.  Moreover, non-U.S. persons generally do not risk exposure to U.S. blocking sanctions under E.O. 14024 for engaging in transactions with blocked persons, where those transactions would not require a specific license if engaged in by a U.S. person.  Note, however, that E.O. 14024 and the directives under E.O. 14024 prohibit any transaction that evades or avoids, has the purpose of evading or avoiding, causes a violation of, or attempts to violate any of the prohibitions of those directives, as well as any conspiracy formed to violate any of the prohibitions of those directives.  OFAC will not view as “evading or avoiding” efforts by non-U.S. persons to comply with U.S. sanctions by replacing sanctioned suppliers or service providers (including financial institutions) with non-sanctioned persons.
 

Released on 02/24/2022

Russian Harmful Foreign Activities Sanctions

979. I am a U.S. person.  Can I rely on a person sanctioned pursuant to Executive Order (E.O.) 14024 in connection with transactions for official business of an international organization, certain humanitarian-related trade, or the response to the Coronavirus Disease 2019 (COVID-19) pandemic?

Yes, U.S. persons supporting activities undertaken for the official business of certain international organizations or entities, certain humanitarian-related trade, or the response to the COVID-19 pandemic may continue to engage in such activity involving persons sanctioned pursuant to E.O. 14024 through a variety of OFAC authorizations or exemptions, as described below.

Consistent with section 9 of E.O. 14024, transactions for the conduct of the official business of the Federal Government or the United Nations (including its specialized agencies, programs, funds, and related organizations) by employees, grantees, and contractors thereof are exempt from the sanctions prohibitions of E.O. 14024.

Additionally, OFAC has issued General License (GL) 5, authorizing transactions for the conduct of the official business of certain international organizations and entities.  

OFAC also issued GL 6, which authorizes, subject to certain conditions, transactions that are ordinarily incident and necessary to:  (1) the exportation or reexportation of agricultural commodities, medicine, medical devices, replacement parts and components for medical devices, or software updates for medical devices to, from, or transiting the Russian Federation; or (2) the prevention, diagnosis, or treatment of COVID-19 (including research or clinical studies relating to COVID-19).

While certain Russian financial institutions are subject to sanctions under E.O. 14024, the financial services sector of the Russian Federation economy is not comprehensively sanctioned (see FAQ 964).  Accordingly, U.S. persons may also use non-sanctioned Russian financial institutions to process these transactions.

Note that the authorizations and exemptions described above do not extend to prohibitions applied to persons sanctioned pursuant to any other sanctions authorities implemented by OFAC, such as E.O. 13662.

Released on 02/24/2022

978. For transactions authorized under Russia-related General Licenses (GL) 6, 7, or 8 what is an example of a permissible funds transfer involving a foreign financial institution sanctioned pursuant to Executive Order (E.O.) 14024? 

GLs 6, 7, and 8  do not authorize a U.S. financial institution to maintain (or open) a correspondent account or payable-through account for or on behalf of entities subject to the prohibitions of Directive 2 under E.O.  14024 , “Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions” (Russia-related CAPTA Directive).  Consequently, in order for a U.S. financial institution to engage in transactions authorized under these GLs (e.g., a funds transfer related to energy), all such funds transfers must be processed indirectly through a non-sanctioned, non-U.S. financial institution.  

Examples of authorized and prohibited funds transfers under GLs 6, 7, and 8 include:

Payment from third-country originator

Authorized payment from third-country originator to beneficiary with an account at a sanctioned institution:

Prohibited payment from third-country originator to beneficiary with an account at a sanctioned institution: 

 

Payment from U.S. originator

Authorized payment from U.S. originator to beneficiary with an account at a sanctioned institution:

Prohibited payment from U.S. originator to beneficiary with an account at a sanctioned institution: 

In each of the above examples, the underlying funds transfer must be authorized under the applicable GL.
 

Released on 02/24/2022

977. What are transactions “related to energy” for purposes of Russia-related General License (GL) 8? 

For the purposes of GL 8,  the term “related to energy” means the extraction, production, refinement, liquefaction, gasification, regasification, conversion, enrichment, fabrication, transport, or purchase of petroleum, including crude oil, lease condensates, unfinished oils, natural gas liquids, petroleum products, natural gas, or other products capable of producing energy, such as coal, wood, or agricultural products used to manufacture biofuels, or uranium in any form, as well as the development, production, generation, transmission, or exchange of power, through any means, including nuclear, thermal, and renewable energy sources.

Released on 02/24/2022

Russian Harmful Foreign Activities Sanctions

976. Can a U.S. financial institution process transactions related to energy where a Russian financial institution sanctioned pursuant to Executive Order (E.O.) 14024 is involved?  

General License (GL) 8  authorizes certain transactions “related to energy” (as defined in the GL; see also FAQ 977) involving: (i) certain Russian financial institutions blocked in February 2022; or (ii) foreign financial institutions determined to be subject to Directive 2 under E.O.  14024, “Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions” (Russia-related CAPTA Directive ).  Specifically, GL 8 applies to the following entities (collectively, “Covered Entities”):

•    State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank (VEB);
•    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; and
•    Any entity owned 50 percent or more, directly or indirectly, individually or in the aggregate, by one of the above entities.

GL 8 does not authorize a U.S. financial institution to maintain (or open) a correspondent account or payable-through account for or on behalf of foreign financial institutions subject to the prohibitions of the Russia-related CAPTA Directive.  Consequently, in order for a U.S. financial institution to engage in transactions authorized by GL 8, all funds transfers related to energy involving one or more Covered Entities must be processed indirectly through a non-sanctioned, non-U.S. financial institution.  Please see FAQ 978 for examples of authorized and prohibited transactions flows under certain GLs, including GL 8.

For purposes of assessing whether certain transactions are authorized under GL 8, U.S. persons may rely upon the information available to them in the ordinary course of business, including reasonable reliance on information about the underlying transaction provided by the parties thereto.  

GL 8 is valid until 12:01 eastern daylight time, June 24, 2022 unless renewed.  Persons unable to wind down prohibited transactions with the Covered Entities by June 24, 2022 are encouraged to approach OFAC, which may consider renewing GL 8 .

Released on 02/24/2022

Russian Harmful Foreign Activities Sanctions

975. Is there a wind-down period for transactions involving the Russian financial institutions blocked in February 2022 pursuant to Executive Order (E.O.) 14024? What transactions are authorized during the wind-down period?  

For certain Russian financial institutions blocked in February 2022 pursuant to E.O. 14024, a short-term wind-down period is authorized.  General License (GL) 3authorizes a wind-down period of 30 days for transactions involving State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank (VEB), and GL 11 authorizes a wind-down period of 30 days for transactions involving VTB Bank Public Joint Stock Company, Public Joint Stock Company Bank Financial Corporation Otkritie, or Sovcombank Open Joint Stock Company.  These authorizations also apply to any entity in which these financial institutions own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest. 

GLs 3 and 11 authorize U.S. persons to engage in transactions ordinarily incident and necessary to exit operations, contracts, or other agreements that were in effect prior to the date of blocking involving the specified blocked Russian financial institutions, provided that such transactions do not involve a debit to a blocked account on the books of a U.S. financial institution (see FAQ 990).  For example, a U.S. financial institution may take steps necessary to collect on outstanding loans made to a blocked person, including exercising rights to any collateral related thereto, as authorized wind-down activity, provided the transaction does not involve a debit to a blocked account on the books of a U.S. financial institution (unless separately authorized).  A U.S. financial institution may also take steps necessary to pay outstanding loans, provided that, if such payment is for the benefit of a blocked person, it must be transferred into a blocked account.  Similarly, a U.S. financial institution may take steps necessary to close a correspondent account maintained for a blocked person; however, funds in the correspondent account may not be returned to the blocked person, and must remain blocked, absent separate authorization from OFAC.

GLs 3 and 11 authorize only new or continued business activities that are ordinarily incident and necessary to wind-down activities.  Wind-down activities do not include the continued processing of funds transfers, securities trades, or other transactions involving a blocked person that were part of ongoing business activities prior to the imposition of sanctions, unless separately authorized (see, e.g., GLs 8, 9, and 10).  Moreover, GLs 3 and 11 do not apply to all Russian financial institutions blocked in February 2022, such as Promsvyazbank Public Joint Stock Company or Joint Stock Commercial Bank Novikombank, or transactions involving other persons blocked pursuant to E.O. 14024, other than the blocked Russian financial institutions specified in GLs 3 and 11.

In addition to GLs 3 and 11, OFAC issued GL 12 to authorize U.S. persons to reject, rather than block, prohibited transactions involving specified blocked Russian financial institutions for 30 days.  This authorizes, for example, a U.S. financial institution to reject, rather than block, an attempted unauthorized funds transfer until the expiration of GL 12.  The authorization provided in GL 3 expires at 12:01 eastern daylight time, March 24, 2022.  The authorizations provided in GLs 11 and 12 expire at 12:01 a.m. eastern daylight time, March 26, 2022.

For more information on the prohibitions that apply to Russian financial institutions blocked pursuant to E.O. 14024 in February 2022, or related authorizations, please see FAQ 974.

For guidance regarding transactions involving securities and derivatives contracts related to the blocked persons listed above, see FAQ 982.
 

Released on 02/24/2022

Russian Harmful Foreign Activities Sanctions

974. What Russian financial institutions were blocked in February 2022 pursuant to Executive Order (E.O.) 14024, and what activities are prohibited as a result?

On February 22, 2022, the Office of Foreign Assets Control (OFAC) designated specified Russian financial institutions pursuant to E.O. 14024 , including the State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank (VEB), Promsvyazbank Public Joint Stock Company, and many of their subsidiaries.  OFAC designated additional Russian financial institutions on February 24, 2022, including VTB Bank Public Joint Stock Company, Public Joint Stock Company Bank Financial Corporation Otkritie (Otkritie), Sovcombank Open Joint Stock Company (Sovcombank), Joint Stock Commercial Bank Novikombank, and many of these financial institutions’ subsidiaries.  As a result, all property and interests in property of these entities in the possession or control of U.S. persons, including U.S. financial institutions, or within U.S. jurisdiction, are blocked and must be reported to OFAC.  In addition, all property and interests in property of any entity that is owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked.  Accordingly, U.S. persons, including U.S. financial institutions, are prohibited from transacting with these entities unless exempt or authorized by OFAC.  

OFAC issued several Russia-related general licenses (GLs)  authorizing transactions involving specified blocked Russian financial institutions, including:
•    GL 2 : authorizing certain transactions involving VEB related to servicing obligations of certain Russian sovereign debt; 
•    GL  3: authorizing the wind down of certain transactions involving VEB for 30 days;
•    GL  11: authorizing the wind down of certain transactions involving VTB Bank Public Joint Stock Company, Otkritie, and Sovcombank for 30 days; and
•    GL  12: authorizing the rejection (rather than blocking) of certain transactions involving VTB Bank Public Joint Stock Company, Otkritie, and Sovcombank for 30 days.

Note that these GLs do not authorize certain activities with all blocked Russian financial institutions; nor does each GL authorize certain activities with the same group of blocked Russian financial institutions.  For example, the GLs listed above do not authorize any transactions involving Promsvyazbank Public Joint Stock Company or Joint Stock Commercial Bank Novikombank, and GLs 2 and 3  relate only to VEB.  

Other GLs  that may be applicable to one or more of the Russian financial institutions blocked in February 2022 include:

•    GL  5: authorizing transactions related to the official business of certain international organizations and other entities; 
•    GL  6: authorizing certain transactions related to the exportation or reexportation of agricultural commodities, medicine, medical devices, replacement parts and components, or software updates, or the prevention, diagnosis, or treatment of COVID-19; 
•    GL  7: authorizing overflight payments, emergency landings, and air ambulance services; 
•    GL  8: authorizing transactions related to energy; 
•    GL  9: authorizing transactions related to dealings in certain debt and equity; and
•    GL  10: authorizing certain transactions related to derivative contracts.

Please consult each GL for further information regarding its scope.  

Additionally, consistent with section 9 of E.O. 14024, transactions for the conduct of the official business of the Federal Government or the United Nations (including its specialized agencies, programs, funds, and related organizations) by employees, grantees, and contractors thereof are exempt from the sanctions prohibitions of E.O. 14024.

Released on 02/24/2022

Russian Harmful Foreign Activities Sanctions

973. I am a U.S. individual or company that maintains an account at a foreign financial institution sanctioned pursuant to Executive Order (E.O.) 14024.  What are my obligations? 

With respect to foreign financial institutions subject to the prohibitions of Directive 2 under E.O. 14024 , “Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions” (Russia-related CAPTA Directive ), including Public Joint Stock Company Sberbank of Russia, obligations under this directive apply to U.S. financial institutions only.  U.S. individuals and companies that are not “U.S. financial institutions,” as defined in the Russia-related CAPTA Directive, are not prohibited from processing transactions involving foreign financial institutions subject to the Russia-related CAPTA Directive.  

With respect to the Russian financial institutions blocked on February 22 and 24, 2022 pursuant to E.O. 14024, General Licenses (GLs) 3 and 11 authorize U.S. persons to engage in transactions ordinarily incident   and necessary to terminate their relationship with specified blocked Russian financial institutions, including withdrawing funds and securities, cancelling letters of credit, and amending or cancelling performance guarantees.  For additional information, please see FAQ 975.  Upon the respective expiration of GLs 3 and 11, U.S. persons are prohibited from transacting with the blocked Russian financial institutions, unless exempt or authorized by OFAC. 
 

Released on 02/24/2022

Russian Harmful Foreign Activities Sanctions

972. Do non-U.S. financial institutions have to comply with the prohibitions of Directive 2 under Executive Order (E.O.) 14024, “Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions” (Russia-related CAPTA Directive)?

Under the Russia-related CAPTA Directive, U.S. financial institutions are prohibited from the opening or maintaining of a correspondent account or payable-through account for or on behalf of, or from processing of a transaction involving, a foreign financial institution determined to be subject to the prohibitions of the Russia-related CAPTA Directive.  The term “U.S. financial institution,” as defined in the directive, includes foreign branches of U.S. financial institutions, but not their foreign subsidiaries.  Note, however, that the Russia-related CAPTA Directive prohibits any transaction that evades or avoids, has the purpose of evading or avoiding, causes a violation of, or attempts to violate any of the prohibitions of this directive, as well as any conspiracy formed to violate any of the prohibitions of this directive.  OFAC will not view as “evading or avoiding” efforts by non-U.S. persons to comply with U.S. sanctions by replacing sanctioned suppliers or service providers (including financial institutions) with non-sanctioned persons.

Released on 02/24/2022

Russian Harmful Foreign Activities Sanctions

971. Are the prohibitions of Directive 2 under Executive Order (E.O.) 14024, “Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions” (Russia-related CAPTA Directive) limited to transactions denominated in U.S. dollars? 

No.  The prohibitions of the Russia-related CAPTA Directive apply with respect to any currency.  For example, a foreign branch of a U.S. financial institution may not open or maintain a correspondent account for or on behalf of, or process a transaction involving, a foreign financial institution determined to be subject to the prohibitions of the Russia-related CAPTA Directive, even if that account is denominated in a currency other than U.S. dollars, such as euros.  

Released on 02/24/2022

Russian Harmful Foreign Activities Sanctions

970. Are foreign financial institutions (FFIs) located outside of Russia potentially subject to the prohibitions of Directive 2 under Executive Order (E.O.) 14024, “Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions” (Russia-related CAPTA Directive)?

Yes.  The prohibitions of the Russia-related CAPTA Directive apply to a U.S. financial institution’s opening or maintaining of a correspondent account or payable-through account for or on behalf of, or processing of a transaction involving, any FFI, wherever located outside of the United States, determined to be subject to the prohibitions of the Russia-related CAPTA Directive, or their property or interests in property—which includes FFIs 50 percent or more owned, directly or indirectly, individually or in the aggregate, by one or more FFIs determined to be subject to the prohibitions of the Russia-related CAPTA Directive.  This includes, for example, banking subsidiaries that are 50 percent or more owned by Public Joint Stock Company Sberbank of Russia and located outside of the United States.  

Released on 02/24/2022

Russian Harmful Foreign Activities Sanctions

969. Does OFAC’s 50 Percent Rule apply to foreign financial institutions listed in Annex 1 to Directive 2 under Executive Order (E.O.) 14024, “Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions” (Russia-related CAPTA Directive)?

Yes.  The prohibitions of the Russia-related CAPTA Directive apply to any foreign financial institution listed in Annex 1 to the Russia-related CAPTA Directive or otherwise determined to be subject to the prohibitions of the Russia-related CAPTA Directive, “or their property or interests in property,” which includes foreign financial institutions 50 percent or more owned, directly or indirectly, individually or in the aggregate, by one or more foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive.  As stated in the Russia-related CAPTA Directive, the prohibitions of this directive apply only with respect to a U.S. financial institution’s opening or maintaining of a correspondent account or payable-through account for or on behalf of, or processing of a transaction involving, a “foreign financial institution,” as defined in the Russia-related CAPTA Directive.  Thus, for purposes of the Russia-related CAPTA Directive, the prohibitions of this directive do not apply to non-“foreign financial institutions,” even if those non-“foreign financial institutions” are 50 percent or more owned, directly or indirectly, individually or in the aggregate, by one or more “foreign financial institutions” determined to be subject to this directive.

Released on 02/24/2022

Russian Harmful Foreign Activities Sanctions

968. What foreign financial institutions are listed in Annex 1 to Directive 2 under Executive Order (E.O.) 14024, “Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions” (Russia-related CAPTA Directive)?  

Annex 1 to the Russia-related CAPTA Directive identifies Public Joint Stock Company Sberbank of Russia as well as many of its foreign financial institution subsidiaries.  The foreign financial institutions listed in Annex 1 have been determined to be subject to the prohibitions of the Russia-related CAPTA Directive for operating or having operated in the financial services sector of the Russian Federation economy, or for being foreign financial institutions that are 50 percent or more owned, directly or indirectly, individually or in the aggregate, by one or more foreign financial institutions subject to the prohibitions of the Russia-related CAPTA Directive.  Please see FAQ 969 regarding the applicability of OFAC’s 50 Percent Rule to these entities.

Released on 02/24/2022

967. What does Directive 2 under Executive Order (E.O.) 14024, “Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions” (Russia-related CAPTA Directive) prohibit?

The Russia-related CAPTA Directive prohibits U.S. financial institutions from:  (i) the opening or maintaining of a correspondent account or payable-through account for or on behalf of foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive; and (ii) the processing of transactions involving foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive.  Please see the Russia-related CAPTA Directive for the definition of the terms “U.S. financial institution” and “foreign financial institution” for purposes of this directive.  Please see FAQ 969 regarding the applicability of OFAC’s 50 Percent Rule with respect to this directive.

Annex 1 to the Russia-related CAPTA Directive lists the foreign financial institutions determined to be subject to the prohibitions as of March 26, 2022.  Foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive, including the foreign financial institutions listed in Annex 1, can be found on the Office of Foreign Assets Control’s (OFAC) List of Foreign Financial Institutions Subject to Correspondent Account or Payable-Through Account Sanctions (CAPTA List).  Relevant entries on the CAPTA List will denote when a foreign financial institution became subject to the prohibitions of the Russia-related CAPTA Directive, as well as when the prohibitions of the Russia-related CAPTA Directive come into effect with respect to that foreign financial institution.

The below table identifies the dates the prohibitions of the Russia-related CAPTA Directive take effect for (i) foreign financial institutions listed in Annex 1 to the Russia-related CAPTA Directive, and (ii) foreign financial institutions otherwise determined to be subject to its prohibitions and added to the CAPTA List.

Foreign Financial Institution Type

Foreign financial institutions listed in Annex 1 to the Russia-related CAPTA Directive

Relevant Sanctions Effective Date

12:01 a.m. eastern daylight time on March 26, 2022

Foreign Financial Institution Type

Foreign financial institution otherwise determined to be subject to the prohibitions of the Russia-related CAPTA Directive

Relevant Sanctions Effective Date

12:01 a.m. eastern time on the date that is 30 days after the date of such determination

U.S. financial institutions must close any correspondent or payable-through account maintained for or on behalf of foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive, or their property or interests in property, by the relevant effective date.  Similarly, as of the relevant effective date, U.S. financial institutions may not process transactions involving foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive, or their property or interests in property, and must reject such transactions unless exempt or authorized by OFAC.

The Russia-related CAPTA Directive does not impose blocking sanctions and, thus, does not require U.S. financial institutions (or U.S. persons) to block the assets of foreign financial institutions determined to be subject to the prohibitions of this directive.  However, U.S. persons should be aware that foreign financial institutions subject to the prohibitions of the Russia-related CAPTA Directive may also be subject to additional prohibitions under other sanctions authorities, such as additional directives under E.O. 14024  or E.O. 13662.

OFAC issued several Russia-related general licenses (GLs) authorizing certain transactions involving the foreign financial institutions subject to the prohibitions of the Russia-related CAPTA Directive, including:

  • GL 5: authorizing transactions related to the official business of certain international organizations and other entities; 
  • GL 6: authorizing transactions related to the exportation or reexportation of agricultural commodities, medicine, medical devices, replacement parts and components, or software updates, or the prevention, diagnosis, or treatment of COVID-19; 
  • GL 7: authorizing overflight payments, emergency landings, and air ambulance services;
  • GL 8: authorizing transactions related to energy; 
  • GL 9: authorizing transactions related to dealings in certain debt and equity; and
  • GL 10: authorizing certain transactions related to derivative contracts. 

For additional information, please see FAQs 976977978979981982 and 990.

Released on 02/24/2022

Russian Harmful Foreign Activities Sanctions

966. What actions did Treasury take in February 2022 related to Russia’s financial services sector pursuant to Executive Order (E.O.) 14024?

Treasury took expansive sanctions actions related to Russia’s financial services sector in February 2022 as detailed below.

  • Financial services sector determination. On February 22, 2022, the Secretary of the Treasury, in consultation with the Secretary of State, issued a determination pursuant to E.O. 14024 that authorizes sanctions against persons determined to operate or to have operated in the financial services sector of the Russian Federation economy (see FAQ 964).
  • Correspondent or payable-through account and payment processing prohibitions. On February 24, 2022, the Office of Foreign Assets Control (OFAC) issued Directive 2 under E.O. 14024, “Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions” (Russia-related CAPTA Directive), which prohibits U.S. financial institutions from: (i) the opening or maintaining of a correspondent account or payable-through account for or on behalf of foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive; and (ii) the processing of transactions involving foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive. Annex 1 to the Russia-related CAPTA Directive identifies Public Joint Stock Company Sberbank of Russia and other foreign financial institutions owned 50 percent or more by this bank as subject to these prohibitions, which become effective on March 26, 2022 (see FAQs 964, 967, 968, 969, 970, 971, 972 and 973).
  • Blocking certain Russian financial institutions. OFAC designated specified Russian financial institutions pursuant to E.O. 14024, including the State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank (VEB), VTB Bank Public Joint Stock Company, Public Joint Stock Company Bank Financial Corporation Otkritie, Promsvyazbank Public Joint Stock Company, Sovcombank Open Joint Stock Company, Joint Stock Commercial Bank Novikombank, and several of these financial institutions’ subsidiaries. As a result, all property and interests in property of these entities in the possession or control of U.S. persons, including U.S. financial institutions, or within U.S. jurisdiction, are blocked and must be reported to OFAC. In addition, all property and interests in property of any entity that is owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked. Accordingly, U.S. persons, including U.S. financial institutions, are prohibited from transacting with these entities unless exempt or authorized by OFAC (see FAQs [NEW FAQs 974, 975, 976, 977, 978, 979, 980, 981, and 982).
  • Expanding sovereign debt prohibitions to include the secondary market. On February 22, 2022, OFAC issued Directive 1A under E.O. 14024, “Prohibitions Related to Certain Sovereign Debt of the Russian Federation” (Russia-related Sovereign Debt Directive), replacing and superseding Directive 1 under E.O. 14024 of April 15, 2021, to extend existing sovereign debt prohibitions to cover participation in the secondary market for ruble or non-ruble denominated bonds issued after March 1, 2022 by the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation (see FAQs 888, 889, 890, 891, 965, and 983).
  • New debt and equity restrictions involving certain Russia-related entities. On February 24, 2022, OFAC imposed additional debt and equity restrictions involving Russia-related entities by issuing Directive 3 under E.O. 14024, “Prohibitions Related to New Debt and Equity of Certain Russia-related Entities” (Russia-related Entities Directive), to prohibit certain dealings by U.S. persons, or within the United States, in new debt of longer than 14 days maturity or new equity of Russia-related entities determined to be subject to the prohibitions of the Russia-related Entities Directive. OFAC determined on February 24, 2022 that the entities listed in Annex 1 to the Russia-related Entities Directive, which include certain major Russian state-owned enterprises and large privately owned financial institutions, are subject to the prohibitions of this directive for new debt or equity issued on or after March 26, 2022 (see 983, 984, 985, 986, 987, 988 and 989).
  • General Licenses (GLs). OFAC issued several Russia-related GLs authorizing certain transactions otherwise prohibited by E.O. 14024 (see FAQs 974, 975, 976, 977, 978, 979, 981, 982, and 990).

and updated:

964. Does the financial services sector determination made by the Secretary of the Treasury, in consultation with the Secretary of State, pursuant to Executive Order (E.O.) 14024 mean that all persons that operate or have operated in the financial services sector of the Russian Federation economy are sanctioned by OFAC?

No.  The Secretary of the Treasury, in consultation with the Secretary of State, has issued a determination pursuant to E.O. 14024 that authorizes sanctions against persons that operate or have operated in the financial services sector of the Russian Federation economy.  The technology sector and defense and related materiel sector of the Russian Federation economy were identified in E.O. 14024 when it was issued on April 15, 2021.  
A sector determination pursuant to E.O. 14024 exposes persons who operate or have operated in an identified sector to sanctions risk; however, a sector determination does not automatically impose sanctions on all persons who operate or have operated in the sector.  Only persons determined, pursuant to E.O. 14024, by the Secretary of the Treasury in consultation with the Secretary of State, or by the Secretary of State, in consultation with the Secretary of the Treasury, to operate or have operated in the above-identified sectors are subject to sanctions.
Persons sanctioned pursuant to E.O. 14024 for operating or having operated in an identified sector are added to one or more OFAC sanctions lists based on the type of sanction, including the Specially Designated Nationals and Blocked Persons List (SDN List), the List of Foreign Financial Institutions Subject to Correspondent Account or Payable-Through Account Sanctions (CAPTA List), and the Non-SDN Menu-Based Sanctions List (NS-MBS List).

Date Updated: February 24, 2022

Updated on 02/24/2022

Belarus Sanctions

956. For the Belarus, Russian Harmful Foreign Activities (Russia) Ukraine-/Russia-related, and Venezuela-related sanctions programs, how does OFAC view modifications to pre-existing loans, contracts, or other agreements to replace London Interbank Offered Rate (LIBOR) as the reference rate? 

In July 2017, the United Kingdom Financial Conduct Authority (FCA) announced the “future cessation and loss of representativeness” of the ICE Benchmark Administration’s 35 global reference rates, the LIBOR rates.  In light of the discontinuation of LIBOR as a benchmark reference rate, OFAC is issuing additional guidance.   

The Belarus, Russia, Ukraine-/Russia-related, and Venezuela-related sanctions programs prohibit U.S. persons from dealing in certain new debt of persons identified as subject to these prohibitions.  In FAQ 944 (Belarus)FAQ 986 (Russia-related)FAQ 371 (Ukraine-/Russia-related), and FAQ 511 (Venezuela-related), OFAC provides examples of new debt, such as “bonds, loans, extensions of credit, loan guarantees, letters of credit, drafts, bankers acceptances, discount notes or bills, or commercial paper” issued on or after various specified dates.  For more information on the effective dates and relevant debt maturities for each of these sanctions programs, please see FAQ 947 (Belarus)FAQ 984 (Russia-related)FAQ 370 (Ukraine-/Russia-related), and FAQ 553 (Venezuela-related).

For the Belarus, Russia, Ukraine-/Russia-related, and Venezuela-related sanctions programs, OFAC has indicated that certain changes to contractual terms of loans, contracts, or other agreements that were entered into prior to the effective date of the relevant sanctions prohibitions could convert pre-existing debt that was not subject to the sanctions prohibitions into new debt that is subject to the sanctions prohibitions.  (See FAQ 947 (Belarus), FAQs 987 and 989 (Russia-related) FAQ 394 (Ukraine-/Russia-related), and FAQ 553 (Venezuela-related).

Loans, contracts, or other agreements that use LIBOR as a reference rate that are modified to replace such benchmark reference rate will not be treated as new debt for OFAC sanctions purposes, so long as no other material terms of the loan, contract, or agreement are modified.

Date Updated: February 24, 2022

Updated on 02/24/2022

Russian Harmful Foreign Activities Sanctions

886. What does Executive Order (E.O.) 14024, “Blocking Property with Respect to Specified Harmful Foreign Activities of the Government of the Russian Federation” do?

E.O . 14024 establishes a new national emergency under which sanctions may be imposed against individuals and entities furthering specified harmful foreign activities of the Russian Federation.  This national emergency is separate from the national emergency relating to the crisis in Ukraine, declared in E.O. 13660 and further addressed in E.O.s 136611366213685, and 13849.   E.O. 14024 addresses national security threats posed by specified harmful foreign activities of the Russian Federation, including:  its efforts to undermine the conduct of free and fair democratic elections and democratic institutions in the United States and its allies and partners; engaging in and facilitating malicious cyber-enabled activities against the United States and its allies and partners; fostering and using transnational corruption to influence foreign governments; pursuing extraterritorial activities targeting dissidents or journalists; undermining security in countries and regions important to United States national security; and violating well-established principles of international law, including respect for the territorial integrity of states. 

Like any other blocking Executive order, E.O. 14024 permits the United States to impose blocking and short-of-blocking sanctions.  The Office of Foreign Assets Control (OFAC) issued several directives under E.O. 14024 specifying certain prohibitions relating to persons determined to be subject to the applicable directive.  OFAC recommends reviewing the sanctions lists maintained by OFAC, including the Specially Designated Nationals and Blocked Persons List (SDN List), the List of Foreign Financial Institutions Subject to Correspondent Account or Payable-Through Account Sanctions (CAPTA List), and the Non-SDN Menu-Based Sanctions List (NS-MBS List), to determine which sanctions are applicable.

Date Updated: February 24, 2022

Updated on 02/24/2022

Ukraine-/Russia-related Sanctions

678. Does the CBW Act Directive prohibit participation in the secondary market for Russian sovereign debt?

No, the CBW Act Directive does not prohibit U.S. banks from participating in the secondary market for Russian sovereign debt.  However, independent of the CBW Act Directive, OFAC has imposed prohibitions on participation in the secondary market of certain Russian sovereign debt pursuant to Russia-related directives under Executive Order (E.O.) 14024  (see FAQ 888 and FAQ 965).

Date Updated: February 24, 2022

Updated on 02/24/2022

Ukraine-/Russia-related Sanctions

676. What do the CBW Act Directive terms “U.S. bank” and “Russian sovereign” mean?

The CBW Act Directive defines the term “U.S. banks.”  This definition is consistent with section 4(c) of E.O. 13883, and with the definition of U.S. financial institution at 31 C.F.R. § 544.311.  The CBW Act Directive defines the term “Russian sovereign” as any ministry, agency, or sovereign fund of the Russian Federation, including the Central Bank of the Russian Federation, the National Wealth Fund, and the Ministry of Finance of the Russian Federation.   This term does not include state-owned enterprises of the Russian Federation.

Independent of the CBW Act Directive, OFAC has imposed prohibitions with respect to certain state-owned enterprises of the Russian Federation pursuant to Directive 3 under E.O. 14024, “Prohibitions Related to New Debt and Equity of Certain Russia-related Entities” (Russia-related Entities Directive ) (see FAQ 984).

Date Updated: February 24, 2022

Updated on 02/24/2022

Ukraine-/Russia-related Sanctions

675. How does OFAC implement sanctions related to U.S. bank loans imposed on Russia pursuant to the CBW Act?

Pursuant to E.O. 13883, 31 C.F.R. § 544.802, and the CBW Act, on August 2, 2019, OFAC issued a Russia-Related Directive (the “CBW Act Directive”), which prohibits U.S. banks from participating in the primary market for non-ruble denominated bonds issued by the Russian sovereign and also prohibits U.S. banks from lending non-ruble denominated funds to the Russian sovereign.  The prohibitions under the CBW Act Directive do not apply to bonds or loans denominated in rubles.  The prohibitions in the CBW Act Directive only apply to “U.S. banks,” as that term is defined in the CBW Act Directive and consistent with section 4(c) of E.O. 13883 and consistent with the definition of U.S. financial institution at 31 C.F.R. § 544.311.  The CBW Act Directive includes a definition of the term “Russian sovereign.”  The CBW Act Directive is effective as of August 26, 2019.

Independent of the CBW Act Directive, OFAC has imposed additional prohibitions with respect to bonds issued by and loans related to certain Government of the Russian Federation entities, as well as prohibitions related to new debt or equity of certain Russia-related entities pursuant to directives under Executive Order (E.O.) 14024 (see FAQ 888FAQ 983, and FAQ 984).

Date Updated: February 24, 2022

Updated on 02/24/2022

Ukraine-/Russia-related Sanctions

371. What does OFAC interpret to be debt and equity?  Are there other prohibited activities under Directives 1, 2, and 3 under Executive Order (E.O.) 13662?  Can U.S. financial institutions continue to maintain correspondent accounts and process U.S. dollar-clearing transactions for the entities subject to the prohibitions of these directives?

The term debt includes bonds, loans, extensions of credit, loan guarantees, letters of credit, drafts, bankers acceptances, discount notes or bills, or commercial paper.  The term equity includes stocks, share issuances, depositary receipts, or any other evidence of title or ownership.

The prohibitions of Directive 1 apply to all transactions involving new debt of specified tenors (see FAQ 370) or new equity; all financing in support of such new debt or new equity; and any dealing in, including provision of services in support of, such new debt or new equity.  For example, for debt that is issued on or after November 28, 2017, on behalf of or for the benefit of a person subject to Directive 1, the maturity of such instrument must be 14 days or less in order for a U.S. person to transact in, to provide financing for, or to otherwise deal in such debt.

For debt that is issued on or after September 12, 2014 but before November 28, 2017, on behalf of or for the benefit of a person subject to Directive 1, the maturity of such instrument must be 30 days or less in order for a U.S. person to transact in, to provide financing for, or to otherwise deal in such debt.  If the terms of the agreement do not subsequently change as described in FAQ 394, then a U.S. person may deal in such debt even after the 14-day debt limit came into effect on November 28, 2017, because such debt would not constitute “new debt” for purposes of the sanctions applicable on or after November 28, 2017.

Likewise, for debt that is issued on or after July 16, 2014 but before September 12, 2014, on behalf of or for the benefit of a person subject to Directive 1, the maturity of such instrument must be 90 days or less in order for a U.S. person to transact in, to provide financing for, or to otherwise deal in such debt.  If the terms of the agreement do not subsequently change as described in FAQ 394, then a U.S. person may deal in such debt even after the revised tenors came into effect on September 12, 2014 or November 28, 2017, because such debt would not constitute “new debt” for purposes of the sanctions applicable on those dates.

The prohibitions of Directive 2 apply to all transactions involving new debt of specified tenors (see FAQ 370); all financing in support of such new debt; and any dealing in, including provision of services in support of, such new debt.

For example, for debt that is issued on or after November 28, 2017, on behalf of or for the benefit of a person subject to Directive 2, the maturity of such instrument must be 60 days or less in order for a U.S. person to transact in, to provide financing for, or to otherwise deal in such debt.

For debt that is issued on or after July 16, 2014 but before November 28, 2017, on behalf of or for the benefit of a person subject to Directive 2, the maturity of such instrument must be 90 days or less in order for a U.S. person to transact in, to provide financing for, or to otherwise deal in such debt.  If the terms of the agreement do not subsequently change as described in FAQ 394, then a U.S. person may deal in such debt even after the 60-day debt limit comes into effect on November 28, 2017 because such debt would not constitute “new debt” for purposes of the sanctions applicable on or after November 28, 2017.

The prohibitions of Directive 3 apply to all transactions involving new debt with a maturity of longer than 30 days; all financing in support of such new debt; and any dealing in, including provision of services in support of, such new debt.

All the prohibitions of these Directives extend to rollover of existing debt, if such rollover results in the creation of new debt with a maturity of longer than the applicable tenor specified in the relevant Directive (see FAQ 394).

Transacting in, providing financing for, or otherwise dealing in any debt issued by, on behalf of, or for the benefit of persons subject to Directives 1, 2, or 3, or equity issued by, on behalf of, or for the benefit of persons subject to Directive 1, is permissible if the debt or equity was issued prior to the date on which the person became subject to the relevant Directive.  In addition, transacting in, providing financing for, or otherwise dealing in debt instruments with tenors shorter than the specified tenors, even if they are issued after the sanctions effective date, is permissible.  Transacting in, providing financing for, or otherwise dealing in new equity instruments of persons subject to Directives 2 and 3 is permissible.  U.S. financial institutions may continue to maintain correspondent accounts and process U.S. dollar-clearing transactions for the persons subject to the Directives, so long as those activities:  (i) do not involve transacting in, providing financing for, or otherwise dealing in transaction types prohibited by these Directives; and (ii) are not prohibited by other sanctions authorities (see, e.g., FAQS 964 and FAQs 967 – 973).

In the case of Directive 1, transacting in, providing financing for, or otherwise dealing in debt with a maturity of 90 days or less (if issued on or after July 16, 2014 but prior to September 12, 2014) or 30 days or less (if issued on or after September 12, 2014 but prior to November 28, 2017) that was issued by, on behalf of, or for the benefit of the persons subject to Directive 1 is not prohibited if the terms of such instruments do not change subsequently (see FAQ 394 for additional detail on what constitutes the changing of terms).  Similarly, in the case of Directive 2, transacting in, providing financing for, or otherwise dealing in debt with a maturity of 90 days or less (if issued on or after July 16, 2014 but prior to November 28, 2017) that was issued by, on behalf of, or for the benefit of the persons subject to Directive 2 is not prohibited if the terms of such instruments do not change subsequently.  Rollovers of such instruments must comply with the new Directive 1 and 2 maturity limits that came into effect on November 28, 2017.

Date Updated: February 24, 2022

Updated on 02/24/2022

Frequently Asked Questions (FAQs).

Whew! I think that’s it – for today…

Links:

OFAC Notice

Russia-related Directives: 2, 3

General Licenses:

New FAQs

Updated FAQs

Categories: Belarus Sanctions CAPTA List Frequently Asked Questions (FAQ) Guidance Licenses Non-SDN Menu-Based Sanctions (NS-MBS) List OFAC Updates Russia sanctions Sanctions Lists Uncategorized

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