Treasury Targets Russian Financial Facilitators and Sanctions Evaders Around the World

Date issued: Apr. 12 2023

You've hit a wall. Sign in if you have an account, learn more about TURBOFAC and subscription options, or purchase access to the text of the document on this page, the native .pdf file, and the associated TURBOFAC original commentary.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (1881 words)

Notes:

1) BACKGROUND

On March 3, 2022, OFAC designated the billionaire Alisher Burhanovich Usmanov (Usmanov) as an SDN, and concurrently issued a GL that was, as of 4-15-23, one-of-a-kind. Russia-related GL 15 authorized “all transactions prohibited by the [RuHSR] involving any entity owned 50 percent or more, directly or indirectly, by Alisher Burhanovich Usmanov that is not listed on OFAC’s [SDN list]…” This GL excluded transactions involving Usmanov himself.

On April 12, 2023, OFAC issued this Press Release, which was issued alongside a State Department press release announcing its own Usmanov-related and other designations (https://www.state.gov/further-curbing-russias-efforts-to-evade-sanctions-and-perpetuate-its-war-against-ukraine-2/), and a UK OFSI press release announcing the Usmanov-related actions taken in coordination with the U.S. government (https://www.gov.uk/government/news/uk-sanctions-abramovich-and-usmanovs-financial-fixers-in-crackdown-on-oligarch-enablers). On the UK side, the designations were cast as a reaction to what it...