RUSSIA-EO14024-31096, Amended Delisting and Unblocking Memorandum in re: Prominvestbank

Date issued: Oct. 17 2024

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TURBOFAC Commentary (1819 words)

Notes:

1) REMOVAL FROM SSI LIST UNDER CAATSA; UNBLOCKING BY OPERATION OF LAW

As described in the Amended Delisting and Unblocking Memorandum, on September 30, 2024, OFAC de-listed a Ukrainian bank that have previously been added to the SDN List for being owned by the Russian SDN VEB Bank. See https://ofac.treasury.gov/recent-actions/20240930. The September 20, 2024 action served to remove the designation pursuant to EO 14024, but not the inclusion of Prominvestbank on the SSI List as an entity subject to SSI Directive 1. According to the DOJ, the reason for OFAC’s September 30, 2024 action was that the bank was nationalized by the Ukrainian government (p. 6, PDF –...