Sanctions Alert: Russia-Related Sanctions

The Special Investigations Unit (SIU) within FINRA’s National Cause and Financial Crimes Detection (NCFC) program is bringing to your attention some additional Russia-related sanctions developments. Please note that these are in addition to those detailed in FINRA Regulatory Notice 22-06. 

On February 26, 2022 the White House released a Joint Statement on Further Restrictive Economic Measures with leaders of the European Commission, France, Germany, Italy, the United Kingdom, and Canada that, amongst other things, stated, “we commit to ensuring that selected Russian banks are removed from the SWIFT messaging system. This will ensure that these banks are disconnected from the international financial system and harm their ability to operate globally.”  According to The White House press briefing on February 26, 2022, “[t]he list of banks that will be de-swifted will be finalized by the EU, since SWIFT is under Belgian jurisdiction.” 

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has also announced a series of additional sanctions related to Russia’s activity in Ukraine.  Specifically, on February 28, 2022, OFAC prohibited United States persons from engaging in transactions with the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation, and added the Russian Direct Investment Fund, its CEO, Kirill Aleksandrovich Dmitriev, its management company, and one of the managing company’s subsidiaries to the Specially Designated Nationals (SDN) List. This follows the imposition of sanctions against Vladimir Putin, Sergei Lavrov, and other members of Russia’s Security Council on February 25, 2022, and the imposition of sanctions against 24 Belarusian individuals and entities on February 24, 2022. 

As noted in FINRA Regulatory Notice 22-06, FINRA encourages member firms to continue to monitor the Department of Treasury’s Office of Foreign Asset Control (OFAC) website for relevant information. If you have general questions about this sanctions alert, please contact Jason Foye, Senior Director, SIU, Member Supervision, at (561) 443-8062 or by email; however, questions about the details of OFAC’s sanctions should be directed to OFAC at (800) 540-6322.