OFAC Sanctions Gazprombank and Further Limits Russia’s Access to International Financial System

On November 21, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated Gazprombank, more than 50 internationally connected small-to-medium Russian banks, more than 40 Russian securities registrars, and 15 Russian finance officials. Treasury Secretary Janet Yellen stated that these sanctions target “Russia’s largest remaining non-designated bank, as well as dozens of other financial institutions and officials in Russia, [and] will further diminish and degrade Russia’s war machine. This sweeping action will make it harder for the Kremlin to evade U.S. sanctions and fund and equip its military.” OFAC has issued a press release that provides a comprehensive overview of these latest sanctions toward Russia’s banking and financial sector.

OFAC designated and placed on the Specially Designated Nationals (SDN) List Gazprombank Joint Stock Company (Gazprombank) and its six foreign subsidiaries – GPB International SA, GPB Financial Services Hong Kong Limited, GPB Financial Services Limited, GPB-DI Holdings Limited, Gazprombank (Switzerland) Ltd, and GPB Africa and Middle East Pty Ltd. For additional details and identifying information on these banks and the other designated financial institutions see here. As a result, all property and interests in property of the designated persons that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. In addition, any entities that are owned, directly or indirectly, individually or in the aggregate, 50% or more by one or more blocked persons are also blocked. Unless authorized by a general or specific license issued by OFAC, or exempt, OFAC’s regulations generally prohibit all transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or otherwise blocked persons. These prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any blocked person and the receipt of any contribution or provision of funds, goods, or services from any such person.

OFAC has issued two new Russia-related general licenses (GL) authorizing U.S. persons to wind down transactions involving Gazprombank, among other financial institutions, and to take the necessary steps to divest from debt or equity issued by Gazprombank.

• GL 113 authorizes the wind down of transactions involving numerous financial institutions placed on the SDN List, including Gazprombank. All transactions with these entities that are ordinarily incident and necessary to the wind down of transactions involving the blocked persons, and any entity in which those blocked persons own, directly or indirectly, individually or in the aggregate, a 50% or greater interest, are authorized through 12:01 a.m. eastern standard time, December 20, 2024.
• GL 114 authorizes certain transactions related to debt or equity of, or derivative contracts involving Gazprombank Joint Stock Company; Interstate Bank; or any entity in which these entities own, directly or indirectly, individually or in the aggregate, a 50% or greater interest. All transactions with these entities that are ordinarily incident and necessary to the divestment or transfer, or the facilitation of the divestment or transfer, of debt or equity issued or guaranteed by these blocked entities to a non-U.S. person are authorized through 12:01 a.m. eastern standard time, December 20, 2024.

In addition, OFAC has amended Russia-related GL 53A to ensure that diplomatic banking activities involving Gazprombank are not disrupted. OFAC has also amended GL55C authorizing certain services related to Sakhalin-2 oil and gas project and involving Gazprombank to continue until June 28, 2025. Certain transactions under each of these general licenses remain unauthorized and therefore each requires close analysis. Additionally, OFAC has issued two new Russia-related Frequently Asked Questions (FAQ 1201, FAQ 1202) and three amended Russia-related Frequently Asked Questions (FAQ 976, FAQ 1096, FAQ 1197) to address these new SDN List designations.

Finally, OFAC has also issued an alert describing sanctions risks for foreign financial institutions related to Russia’s System for Transfer of Financial Messages (SPFS, short for Sistema Peredachi Finansovykh Soobshcheniy), which Russia created as an alternative to the SWIFT network, and that OFAC states has been used to evade sanctions. OFAC notes that it views joining SPFS “after publication of this alert as a red flag and is prepared to more aggressively target foreign financial institutions that take such action.”