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Russia Sanctions Now: What Just Changed, What It Means for Your Money Flows, and What To Do Next | On-Demand Webinar + On-Demand Course Access
Executive summary
- OFAC’s authority to hit foreign financial institutions (FFIs) that support Russia’s war economy—via EO 14114’s amendments to EO 14024—is the defining compliance risk of 2024–25.
- Licensing remains fluid.
- Energy & shipping are still prime targets – the January 10, 2025 package hit major oil firms, Sovcomflot’s fleet, and facilitators across insurers, traders, and logistics.
- Case-by-case relief exists (e.g., NIS waiver for Serbia to Oct 8, 2025).
What’s new?
- GL 13O renewed (Sep 29, 2025) + FAQ 999 & 1118 tweaks → operations/legal should re-confirm what your bank labels as permissible “administrative transactions” with Directive 4-blocked banks.
- Continuing Russia designations (e.g., Sept 11, 2025 tranche) targeting individuals, entities, and vessels—keep screening logic updated to catch vessel renamings/IMO changes and affiliates.
- EU track (context for multinationals): the proposed 19th EU package contemplates phasing out Russian LNG by 2027 and new pressure on third-country trade and crypto facilitators—important for group-wide policies and EU-touching transactions.