OFAC FAQ (Removed) # 1082 - Russian Harmful Foreign Activities Sanctions

Date issued: Sep. 15 2022

Last substantive commentary amendment:
Feb. 03 2024

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TURBOFAC Commentary (677 words)

2-23-24 UPDATE - This FAQ was removed from OFAC's website in light of the designation of NSPK pursuant to EO 14024. The comments below have not been amended to reflect this fact.

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Notes:

1) For relevant background, see "Russia vows to continue Mir bankcard expansion after new U.S. sanctions" (September 16, 2022; Reuters - https://www.reuters.com/business/finance/russia-vows-continue-mir-card-expansion-after-new-us-sanctions-2022-09-16/) and "US and EU step up pressure on Turkey over Russia sanctions" (September 15, 2022; FT - https://www.ft.com/content/95243a73-22c8-447e-bbae-a10a206d7e9e). "Five of Turkey’s largest banks, VakıfBank, Ziraat Bank, İş Bank, DenizBank and Halkbank, are members of the Mir payment system, which was developed by Russia’s central bank as a domestic alternative to Visa and Mastercard...Wally Adeyemo, deputy US treasury secretary, wrote to Turkish businesses last month warning them of 'Russia’s attempts to use your country to evade sanctions' and the risks of 'conducting...