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1148. What activities could expose a foreign financial institution (FFI) to sanctions under section 11 of Executive Order (E.O.) 14024, as amended by E.O. 14114?


FFIs may be sanctioned for engaging in certain transactions, or providing any service, involving Russia’s military-industrial base.  For example, FFIs may be sanctioned for conducting any significant transaction(s) for any person that has been blocked pursuant to E.O. 14024.  FFIs may also be sanctioned for maintaining accounts, transferring funds, or providing other financial services to persons, either inside or outside Russia, for any person blocked pursuant to E.O. 14024, as well as to any person operating in the following sectors of the Russian Federation economy: technology, defense and related materiel, construction, aerospace, or manufacturing. This also includes facilitating the sale, supply, or transfer, directly or indirectly, to the Russian Federation of certain items critical to Russia’s war effort identified in the determination of December 22, 2023 pursuant to subsection 11(a)(ii) of E.O. 14024 (Russia Critical Items Determination), such as certain machine tools, semiconductor manufacturing equipment, electronic test equipment, propellants and their precursors, lubricants and lubricant additives, bearings, advanced optical systems, and navigation instruments.

For additional information and examples of the types of activities that would expose FFIs to sanctions risks, see OFAC’s Advisory to Foreign Banks on Russia Sanctions Risks. For additional information on the specific items identified on the Russia Critical Items Determination, see FAQ 1150.

Updated: June 12, 2024

Date Released
December 22, 2023