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, or learn more about TURBOFAC and subscription options.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (1834 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...