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Russian Harmful Foreign Activities Sanctions

978. For transactions authorized under Russia-related General Licenses (GL) 6D, 7A, or GL 115B what is an example of a permissible funds transfer involving a foreign financial institution sanctioned pursuant to Executive Order (E.O.) 14024?

GLs 6D, 7A, or 115B 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 6D, 7A, and 115B include:

Payment from third-country originator

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

Step process starting from Third-Country Originator, to Third-Country Originating Bank, to U.S. Correspondent, to another U.S. Correspondent, to Third-Country Intermediary Bank, to Target Entity, and finally to Beneficiary

Prohibited payment from third-country originator to beneficiary with an account at a sanctioned institution:
Step process starting from Third-Country Originator, to Third-Country Originating Bank, to U.S. Correspondent, to another U.S. Correspondent, to Target Entity, and finally to Beneficiary
 

Payment from U.S. originator

Authorized payment from U.S. originator to beneficiary with an account at a sanctioned institution:
Step process starting from U.S. Person Originator, to U.S. Person Financial Institution, to U.S. Correspondent, to Third-Country Intermediary Bank, to Target Entity, and finally to Beneficiary

Prohibited payment from U.S. originator to beneficiary with an account at a sanctioned institution:
Step process starting from U.S. Person Originator, to U.S. Person Financial Institution, to U.S. Correspondent, to Target Entity, and finally to Beneficiary

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

Updated: June 27, 2025

February 24, 2022