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1148. What activities could expose a foreign financial institution (FFI) to sanctions under section 11 of Executive Order (E.O.) 14024, as amended by E.O. 14114?
FFIs may be sanctioned for engaging in certain transactions, or providing any service, involving Russia’s military-industrial base. For example, FFIs may be sanctioned for conducting any significant transaction(s) for any person that has been blocked pursuant to E.O. 14024. FFIs may also be sanctioned for maintaining accounts, transferring funds, or providing other financial services to persons, either inside or outside Russia, for any person blocked pursuant to E.O. 14024, as well as to any person operating in the following sectors of the Russian Federation economy: technology, defense and related materiel, construction, aerospace, or manufacturing. This also includes facilitating the sale, supply, or transfer, directly or indirectly, to the Russian Federation of certain items critical to Russia’s war effort identified in the determination...
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1) Refer to comments to EO 14114 for more on the EO. This FAQ does not provide interpretive guidance of any sort.
2) FAQ amended on 6-12-24 to reflect OFAC’s expansion of the definition of the term “military-industrial base” to one that includes all “all persons whose property and interests in property are blocked pursuant to E.O. 14024,” as opposed to only those designated pursuant to EO 14024 for operating in certain specified sectors. FAQ also amended to specify (consistent with the text of the EO) that “providing any service” involving Russia’s military-industrial base is potentially sanctionable. See comments to EO 14114 for further discussion.