License No. RUSSIA-EO14024-2022-XXXXXX

Date issued: Apr. 10 2025

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TURBOFAC Commentary (496 words)

Consolidated Comment on License No. RUSSIA-EO14024-2022-XXXXXX, License No. RUSSIA-EO14024-2024-XXXXXX, License No. RUSSIA-EO14024-2025-XXXXXX and License No. RUSSIA-EO14024-202X-XXXXXX

1) Read in conjunction with General Note on Short Licenses for the Unblocking of Funds Transfers / Accounts Blocked Erroneously or Otherwise (System Ed. Note).These four "short form" unblocking licenses issued to banks were obtained and released by an individual that serves as a Russian OFAC unblocking consultant (see https://web.archive.org/web/20250522025015/https://ohmyswift-consulting.com/consultation/ofac).

2) ROSBANK-RELATED LICENSES

Three of these licenses were issued to Standard Chartered Bank (presumably its U.S. entity as evidenced by License No. RUSSIA-EO14024-202X-XXXXXX) in connection with funds transfers from July and August of 2022 for which the originating bank was Rosbank. Rosbank was sanctioned by OFAC on December 15, 2022. For two of these licenses...