On November 21, 2024, the U.S. Treasury Office of Foreign Assets Control (OFAC) designated Gozprombank Joint Stock Company along with its six international subsidiaries and 50 other Russian banks as blocked entities under Executive Order (E.O.) 14024. The sweeping move by OFAC was described as necessary to further limit the ability of the Russian state to finance the war effort in Ukraine and evade U.S. and international sanctions. In the press release OFAC placed special attention on Gozprombank and its six international subsidiaries (as noted below) who were singled out for supporting the war effort
- GPB International SA (Luxumbourg based)
- GPB Financial Services Hong Kong Limited
- GPB Financial Services Limited (Cyprus based)
- GPB-DI Holdings Limited (Cyprus based)
- Gazprombank (Switzerland) Ltd
- GPB Africa and Middle East Pty Ltd(South Africa based)
The following additional 50 small to medium sized Russian banks were also designated under E.O. 14024 under this new OFAC ruling and have been effectively blocked.
- Aktsionernoe Obshchestvo Bank Agroros is a bank headquartered in Saratov, Russia.
- Bank Iturup LLC is a bank headquartered in Yuzhno-Sakhalinsk, Russia.
- BBR Bank Joint Stock Company is a bank headquartered in Moscow, Russia.
- BCS Bank AO is a bank headquartered in Moscow, Russia.
- Bratsky Narodny Bank JSC is a bank headquartered in Bratsk, Russia.
- Centrocredit Bank is a bank headquartered in Moscow, Russia.
- Commercial Bank Energotransbank Joint Stock Company is a bank headquartered in Kaliningrad, Russia.
- Commercial Bank Khlynov Joint Stock Company is a bank headquartered in Kirov, Russia.
- Commercial Bank Kremlyovskiy is a bank headquartered in Moscow, Russia.
- Commercial Joint Stock Bank Viking is a bank headquartered in Saint Petersburg, Russia.
- Corporate Finance Bank LLC is a bank headquartered in Moscow, Russia.
- Evrofinance Mosnarbank is a bank headquartered in Moscow, Russia. Evrofinance Mosnarbank was previously designated pursuant to E.O. 13850.
- Fora Bank Joint Stock Commercial Bank is a bank headquartered in Moscow, Russia.
- Garant Invest Bank Joint Stock is a bank headquartered in Moscow, Russia.
- Interstate Bank is a bank headquartered in Moscow, Russia.
- Joint Stock Commercial Bank National Reserve Bank Joint Stock Company (NRB)is a bank headquartered in Moscow, Russia. Daniel Haindl (Haindl) is the Senior Vice President of NRB. In his role at NRB, Haindl has been involved in a sanctions evasion scheme.
- Joint Stock Commercial Bank Slavia Joint Stock Company is a bank headquartered in Moscow, Russia.
- Joint Stock Commercial Mortgage Bank Akibank Public Joint Stock Company is a bank headquartered in Naberezhnye Chelny, Russia.
- Joint Stock Company Auto Finance Bank is a bank headquartered in Moscow, Russia.
- Joint Stock Company Bank Accept is a bank headquartered in Novosibirsk, Russia.
- Joint Stock Company Bank Dom RF is a bank headquartered in Moscow, Russia.
- Joint Stock Company Bank Finservice is a bank headquartered in Moscow, Russia.
- Joint Stock Company Bank United Capital is a bank headquartered in Saint Petersburg, Russia.
- Joint Stock Company Coalmetbank is a bank headquartered in Chelyabinsk, Russia.
- Joint Stock Company Commercial Bank Ural FD is a bank headquartered in Perm, Russia.
- Joint Stock Company Guta Bank is a bank headquartered in Moscow, Russia.
- Joint Stock Company NS Bank is a bank headquartered in Moscow, Russia.
- Joint Stock Company Public Trust Bank is a bank headquartered in Moscow, Russia.
- Joint Stock Company Royal Credit Bank is a bank headquartered in Vladivostok, Russia.
- Joint Stock Company Severgazbank is a bank headquartered in Vologda, Russia.
- Joint Stock Investment Commercial Bank Eniseisk United Bank is a bank headquartered in Krasnoyarsk, Russia.
- JSC Exi Bank is a bank headquartered in Saint Petersburg, Russia.
- JSCB Energobank is a bank headquartered in Kazan, Russia.
- Kamsky Commercial Bank is a bank headquartered in Naberezhnye Chelny, Russia.
- Limited Liability Company Bank Orange is a bank headquartered in Saint Petersburg, Russia.
- Limited Liability Company Bank Round is a bank headquartered in Moscow, Russia.
- Limited Liability Company Krona Bank is a bank headquartered in Irkutsk, Russia.
- MB Bank is a bank headquartered in Moscow, Russia.MB Bank, also known as Mir Business Bank, is the Russia-based wholly-owned subsidiary of Iran’s Bank Melli Iran. MB Bank was previously designated previously designated pursuant to E.O. 13224 and E.O. 13582.
- National Standard Bank Joint Stock Company is a bank headquartered in Moscow, Russia.
- New Moscow Bank is a bank headquartered in Moscow, Russia.
- NK Bank Joint Stock Company is a bank headquartered in Moscow, Russia.
- Primorsky Territorial Commercial Bank Society with Limited Liability is a bank headquartered in Vladivostok, Russia.
- Public Joint Stock Commercial Bank Derzhava is a bank headquartered in Moscow, Russia.
- Public Joint Stock Company Bank Alexandrovsky is a bank headquartered in Saint Petersburg, Russia.
- Public Joint Stock Company Bank Sinara is a bank headquartered in Yekaterinburg, Russia.
- Public Joint Stock Company Finstar Bank is a bank headquartered in Saint Petersburg, Russia.
- Public Joint Stock Company Metkombank is a bank headquartered in Kamensk-Uralskiy, Russia.
- Public Joint Stock Company National Bank Trust is a bank headquartered in Moscow, Russia.
- Public Joint Stock Social Commercial Bank of Primorye Primsotsbank is a bank headquartered in Vladivostok, Russia.
- Rossita Bank is a bank headquartered in Moscow, Russia.
- Russian Public Joint Stock Commercial Roads Bank is a bank headquartered in Moscow, Russia.
- Russian Universal Bank is a bank located in Moscow, Russia.
- Vitabank PJSC is a bank headquartered in Podolsk, Russia.
- Waybank JSC is a bank headquartered in Moscow, Russia.
In addition, sanctions were expanded to include an extensive list of dozens of Russian securities registrars as well as four Russian nationals working in the foreign offices of VTB and Sberbank.
TSI Global Consulting Recommended Actions in Light of Recent OFAC Tightening:
Given this latest extreme “tightening” of US and western bank ties to the Russian financial system, and in light of a current situation in which a TSI Global Consulting client company operating in the agricultural sector is having extreme difficulty arranging wire payments for a licensed transaction using one of the very few non-sanctioned banks that still exist in Russia, we highly recommend that potential BIS licensed and OFAC authorized export deals with Russian buyers are structured in a manner whereby payment for exports originates and goes through offshore western banks that fully adhere to US and western sanctions.
Taking this one step further, based on this latest OFAC action, we recommend screening foreign banks not only to ensure such banks are not subject OFAC’s Russian sanctions, but also to ensure they are not part of the Russian System for Transfer of Financial Messages (SPFS), the Russian alternative to SWIFT which serves as a red flag for sanctions evasion and possible future OFAC actions. Do all screening, due diligence, and structuring of offshore banking arrangements PRIOR TO applying for Russia related export licenses with BIS.
