US Sanctions Transkapitalbank, Virtual Currency Mining Company and Evasion Network – Export Controls and Trade and Investment Sanctions

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Today, the United States Office of Foreign Assets Control (OFAC) designated Transkapitalbank, a private Russian commercial bank, and its subsidiary, Investtradebank, as Specially Designated Nationals (SDN). OFAC imposed blocking sanctions on the banks due to their role in facilitating US dollar payments for sanctioned customers and developing systems designed to evade US and EU sanctions. US persons are generally prohibited from doing business with banks or with entities 50% or more owned by newly designated SDNs without OFAC authorization. U.S. persons must also formally “freeze” (freeze and report) any property or interest in bank property that is in their possession or control.

OFAC issued two temporary general licenses authorizing limited continuing relationships with Transkapitalbank. First, OFAC issued a general license authorizing certain transactions involving Transkapitalbank to or from Afghanistan to support humanitarian relief efforts in that country. Second, OFAC issued a general license authorizing U.S. persons to terminate certain transactions involving Transkapitalbank and its majority-owned entities until 12:01 a.m. EDT on May 20, 2022, subject to limitations specified in the license.


OFAC also today designated virtual currency mining company Bitriver AG and its Russian subsidiaries as SDN. As with the action against Transkapitalbank, Bitriver’s designation broadly prohibits US persons and persons in the United States from engaging in transactions involving Bitriver or its assets and interests in property, and requires US persons to formally freeze any assets or interest in any Bitriver property in their possession or control. OFAC appointed Bitriver to prevent the company from obtaining imported computer equipment and making fiduciary payments necessary to support its business, reducing Russia’s ability to use virtual currencies to offset the impact of sanctions .

escape network

Separately, OFAC updated sanctions against Russian oligarch Konstantin Malofeyev and named a network of individuals and entities that support Malofeyev’s activities, including those related to sanctions evasion and antitrust campaigns. disinformation.

New credit card FAQ

Today, OFAC also released a new FAQ clarifying the obligations of credit card scheme operators under US sanctions related to Russia and Belarus. US credit card operators and acquirers are prohibited from processing transactions involving listed foreign financial institutions without OFAC authorization. OFAC also indicates that non-US operators whose payment cards are issued by listed foreign financial institutions would be at risk of US sanctions to the extent that these payment cards are used in the United States. Accordingly, OFAC encourages U.S. persons, including credit card scheme operators, to exercise caution and adopt due diligence processes for transactions with non-U.S. carriers known to host payment cards. issued by sanctioned financial institutions whose cards are accepted in the United States.

The content of this article is intended to provide a general guide on the subject. Specialist advice should be sought regarding your particular situation.

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