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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. of December 22, 2023?
FFIs may be sanctioned for engaging in certain transactions involving Russia’s military-industrial base. For example, FFIs may be sanctioned for processing any significant transaction(s) for persons that have been designated for operating or having operated in the technology, defense and related materiel, construction, aerospace, or manufacturing sectors, or additional sectors as may be determined to be part of the military-industrial base (the specified sectors).
FFIs may also be sanctioned for processing any significant transaction(s), or providing any service, involving Russia’s military-industrial base (see FAQ 1151). This includes maintaining accounts, transferring funds, or providing other financial services to persons, either inside or outside Russia, that operate in the specified sectors of the Russian Federation economy. This also includes facilitating...
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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.