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:
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.
Updated: June 27, 2025