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"We understand that Mongolia is facing difficulties in making payments to Russia related to essential imports, particularly energy, and that Mongolian financial institutions (including the Bank of Mongolia) may rely on Gazprombank JSC and its six foreign subsidiaries noted above (collectively, “Gazprombank”) to make payments for energy, specifically crude oil, petroleum products, electricity, and natural gas. In light of Mongolia’s unique and challenging energy situation, its efforts to abide by U.S. sanctions, and the limited alternatives for obtaining and paying for energy, OFAC is providing this guidance that non-U.S. persons would not be exposed to U.S. sanctions under E.O. 14024 for transactions involving Gazprombank that are ordinarily incident and necessary to payments for crude oil, petroleum products, electricity, and natural gas for consumption within Mongolia. Non-U.S. financial institutions would not risk exposure to U.S. sanctions under E.O. 14024 for processing such payments involving Gazprombank. This guidance...
1) The excerpt is of a "comfort letter" issued by the Treasury and reported by a prominent Mongolian news source, presumably issued to the Bank of Mongolia (Mongolian Central Bank) in connection with the then-recent blocking of Gazprombank and subjecting of Gazprombank to secondary sanctions. (See Consolidated Comment on Section 11 of EO 14024, as Amended). We are in the process of attempting the confirm the authenticity of the excerpt, but if it is doctored, it is certainly well done as the language is what we would expect from a letter of this sort (notwithstanding that it is the only public example of a letter of this sort, and therefore newsworthy enough to include int he Research System as a reported except).