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974. What Russian financial institutions were blocked in February 2022 pursuant to Executive Order (E.O.) 14024, and what activities are prohibited as a result?
On February 22, 2022, the Office of Foreign Assets Control (OFAC) designated specified Russian financial institutions pursuant to E.O. 14024 , including the State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank (VEB), Promsvyazbank Public Joint Stock Company, and many of their subsidiaries. OFAC designated additional Russian financial institutions on February 24, 2022, including VTB Bank Public Joint Stock Company, Public Joint Stock Company Bank Financial Corporation Otkritie (Otkritie), Sovcombank Open Joint Stock Company (Sovcombank), Joint Stock Commercial Bank Novikombank, and many of these financial institutions’ subsidiaries. As a result, all property and interests in property of these entities in the possession or control of U.S. persons, including U.S. financial institutions, or within U.S. jurisdiction, are blocked and must be reported to...
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1) Of particular note here is the statement that "all property and interests in property of these entities in the possession or control of U.S. persons, including U.S. financial institutions, or within U.S. jurisdiction, are blocked and must be reported to OFAC." The term "property and interests in property" normally refers to all property "in which" a blocked person has an interest. See e.g. General Note on the 300-level definition of ‘Blocked account; blocked property’. However, the GLs referenced in the FAQ have the effect of authorizing transactions involving certain property in which blocked person have an interest, and the GLs took effect concurrently with the blocking. Must property within the scope of the wind-down GLs be reported even if it is "unblocked" by the wind-down GLs? See 501.603. The FAQ suggests that, where a wind-down GL authorizes...