The United States continues to expand sanctions on Russia in response to its invasion of Ukraine and has expanded secondary sanctions targeting Russia. To this end, the Office of Foreign Assets Control (“OFAC”) has imposed secondary sanctions on any foreign financial institution that facilitates prohibited transactions. In light of the OFAC prohibitions on certain transactions related to Russia, specifically in certain critical goodsA and operating or having operated in certain sectorsB in Russia, in that case bank will not support, facilitate or process any transaction or banking service that relates directly or indirectly to transactions involving the critical goodsA and/or sectorsB in Russia (please refer to Annex A and B).
Prior to entering into any transaction or service, one should ensure it is not
prohibited by any such sanctions.
Annex A
The Russia Critical Items Determination issued by U.S. Office of Foreign Assets Control, pursuant to subsection 11(a)(ii) of Executive Order 14024 identifies certain items that support Russia’s military-industrial base. Please note that the list is subject to periodic updates or additional determinations may be issued from time to time.
Annex B
Technology sector of the Russian Federation economy: The term technology sector of the Russian Federation economy includes activities such as the production, procurement,
research, development, design, engineering, testing, servicing, financing, distribution, use, or transport involving the Russian Federation, of software, equipment, electronics, items, tools, materials, or devices, and any components, parts, or accessories of the foregoing, related to the fields of computing, engineering, applied mathematics, or applied sciences involving the Russian Federation and any related activities, including the provision or receipt of goods or services involving the technology sector of the Russian Federation economy.
Defense and related material sector of the Russian Federation economy: The term defense and related materiel sector of the Russian Federation economy includes military, armed forces, or security forces of or within the Russian Federation; the use of arms or related materiel by military, armed forces, or security forces of or within the Russian Federation; any person designing, developing, manufacturing, supplying, financing, procuring, or distributing goods, services, or technology to, from, or involving military, armed forces, or security forces of or within the Russian Federation; and any related activities, including the provision or receipt of goods, services, or technology involving the defense and related materiel sector of the Russian Federation economy. The term defense and related materiel sector of the Russian Federation economy also includes acquisition, possession, procurement, research, design, development, testing, evaluation, manufacture, maintenance, upgrade or refurbishment, shipping, supply, sale, transfer, or storage to, from, within, for, transiting, or on behalf of the Russian Federation of arms or related materiel of all types; enablers, aggregates, components, parts, as well as related documentation and instructions for any such arms or related materiel; or training for
the use of included systems, provision of simulation equipment, documentation (including
training manuals, maintenance orders, or technical bulletins), prototypes, software upgrades, and licensing and manufacturing agreements for such items.
Construction sector of the Russian Federation economy: The term construction sector of the Russian Federation economy includes activities such as the production, procurement, devising, framing, design, testing, financing, distribution, or transport involving the Russian Federation, of goods, services, or technology to fabricate, shape, alter, maintain, or form any buildings or structures, including the on-site development, assembly, or construction of residential, commercial, or institutional buildings, or of transportation infrastructure, in the Russian Federation; and any related activities, including the provision or receipt of goods, services, or technology to, from, or involving the construction sector of the Russian Federation economy.
Aerospace sector of the Russian Federation economy: The term aerospace sector of the
Russian Federation economy includes activities such as the production, procurement,
development, design, testing, servicing, financing, distribution, use, or transport involving the Russian Federation and its airspace, of aircraft or any other device used or intended to be used for flight or activities in the air or in space, missiles, unmanned aerial vehicles, space-based vehicles, satellites, high-altitude balloons, any other device that operates above the surface of the earth, and any items, components, parts, or accessories intended for the foregoing; airports or any other area of land or water used or intended to be used for a purpose related to the aerospace sector of the Russian Federation; and any related activities, including the provision or receipt of goods, services, or technology involving the aerospace sector of the Russian Federation economy.
Manufacturing sector of the Russian Federation economy: The term manufacturing sector of the Russian Federation economy includes activities such as the creation, modification, repair, testing, or financing, of goods by manual labor or machinery involving the Russian Federation and any related activities, including the provision or receipt of goods, services, or technology to, from, or involving the manufacturing sector of the Russian Federation economy. Note that persons conducting or facilitating transactions that are exempt or authorized by OFAC—such as those related to the provision of agricultural commodities, food, medicine, or medical devices, or related to energy—will not be subject to sanctions under E.O. 14024.
Extracted from: 1126 | Office of Foreign Assets Control (treasury.gov)
Pushkar Mer 