Pursuant to the RuHSR and BSR, U.S. persons, including U.S. operators of credit card systems and U.S. acquirers, are prohibited from processing transactions involving certain sanctioned foreign financial institutions, unless exempt or authorized by OFAC. Non-U.S. operators of credit card systems whose payment cards are issued by sanctioned foreign financial institutions may also be in violation of OFAC-administered sanctions regulations if they allow those cards to be used in the United States.
OFAC encourages U.S. persons, including U.S. operators of credit card systems and U.S. acquirers, to exercise caution and due diligence in dealing with non-U.S. operators of credit card systems that are known to host payment cards issued by sanctioned foreign financial institutions and whose payment cards are accepted in the United States. Examples of due diligence measures may include requesting Bank Identification Numbers (BINs) associated with sanctioned foreign financial institutions, disabling those BINs from operation in the United States, and requesting that non-U.S. operators of credit card systems prevent the use of payment cards issued by sanctioned foreign financial institutions in the United States at the network level.