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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?

Answer

FFIs may be sanctioned for engaging in certain transactions involving Russia’s military-industrial base.  For example, FFIs may be sanctioned for processing any significant transaction(s) for persons that have been designated for operating or having operated in the technology, defense and related materiel, construction, aerospace, or manufacturing sectors, or additional sectors as may be determined to be part of the military-industrial base (the specified sectors).

FFIs may also be sanctioned for processing any significant transaction(s), or providing any service, involving Russia’s military-industrial base (see FAQ 1151).  This includes maintaining accounts, transferring funds, or providing other financial services to persons, either inside or outside Russia, that operate in the specified sectors of the Russian Federation economy.  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 foreign financial institutions 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

Date Released
December 22, 2023