Russia Sanctions Now: What Changed & What To Do | Live CLE International Trade Law Webinar

Russia Sanctions Now: What Just Changed, What It Means for Your Money Flows, and What To Do Next | Live CLE International Trade Law Webinar

Broadcast Date: Thursday, October 30, 2025, from 12:00 PM to 1:00 PM (ET) | On-Demand 24hrs Later

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. Expect account restrictions or full blocking if you facilitate transactions for Russia’s military-industrial base (directly or indirectly).  
• Licensing remains fluid. OFAC just extended GL 13O (admin transactions under Directive 4, EO 14024), and continues to fine-tune FAQs—small text changes but big operational consequences when banks rely on them.  
• 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—raising costs and due-diligence burdens for anyone touching crude flows, freight, or maritime services.  
• Case-by-case relief exists (e.g., NIS waiver for Serbia to Oct 8, 2025), illustrating how specific licenses/waivers can stabilize critical infrastructure while sanctions pressure remains. Use these as templates for risk-mitigating asks.  

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; don’t assume your previous memos still hold.  
• 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.

Who Should Attend:

• Compliance and Risk Officers
• International Trade Lawyers
• Financial Managing Officers
• Chief Financial Officers
• Top Level Management

Agenda:

Aleksey Shtivelman, Partner, Shutts & Bowen LLP

1) Secondary-sanctions risk for FFIs—and anyone banking with them

• Authority: EO 14114 empowers OFAC to sanction Foreign Financial Institutions (FFIs) which conduct or facilitate significant transactions for any EO 14024-blocked person (not just the defense sector). Outcome: correspondent/payable-through account loss in the U.S. or full blocking. Implication: foreign banks, MSBs, and fintechs must police their own customers’ Russia nexus—not just U.S. persons.  
• OFAC advisory & FAQs (June 2024–June 2025): OFAC explicitly warns on evasion networks, reiterates that humanitarian, ag/med trade remains allowed, and ties diligence to “Russia critical items” & BIS Common High Priority Items lists—your item-level screening and deal narratives matter.  
• Action items to say on stage:
  
  • Map FFI exposure: identify non-U.S. correspondents processing Russia-adjacent flows; require attestations and escalate enhanced due diligence (EDD).
  • Narrative memos for each at-risk transaction (who/what/why allowed), with item-level export control checks embedded.

2) Energy, shipping & payments—pressure points to watch

• Jan 10, 2025 measures broadened pressure on oil producers, Sovcomflot (69 vessels), insurers, traders, and shadow-fleet nodes. Practical result: more KYC on tonnage, insurers, ports, and AIS behavior; higher re-routing costs; and more false-positive headaches for banks.  
• Illustrative licensing/waiver practice: NIS (Serbia) waiver to Oct 8, 2025 keeps regional refining and the JANAF pipeline flowing—lesson: critical-infrastructure arguments can win narrow relief; structure requests with government-interest framing.  
• Earlier finance shock still relevant: MOEX & related infra designations (June 2024) complicated FX clearing, hedging, and securities settlement for Russia-facing firms; many treasuries had to re-paper. If your policies predate that action, assume gaps.  

3) Licensing & GL updates—why small words matter

• GL 13O (Sep 29, 2025): re-authorizes certain administrative transactions with Directive 4-blocked banks (e.g., account fees, taxes) but not commercial facilitation. Refresh your “admin vs. commercial” matrix and make sure ops teams aren’t over-relying on legacy GL language.  
• Energy GLs: Remember GL 8L (Jan 10, 2025) wind-down authority—helpful for de-risking exits, but timelines are tight; ensure you can document cessation steps.  
• Practical takeaway: build a “GL tracker” with renewal dates, scope notes, and owner sign-offs; treat FAQ edits as change-management events, not FYIs.

4) Enforcement trends—what OFAC is signaling

• Settlements continue (e.g., ShapeShift AG, Sept 23, 2025) reinforcing expectations around virtual-asset compliance, geo-blocking, and sanctions screening for tokenized products. Crypto rails ≠ safe harbor.  
• Maritime deception indicators (dark activity, STS transfers, spoofing), IT-services bans, and software provisioning to Russia all remain priority evasion vectors—OFAC has called these out repeatedly since mid-2024.  

5) Case studies

• Cases to be discussed

Practical implication and compliance playbook

1. Banking/Payments
   
   • Stand up an FFI Risk Desk with authority to halt Russia-adjacent payments pending narrative review.
   • Require attestations from non-U.S. correspondents on EO 14114 exposure.  

2. Trade & Shipping
   
   • Integrate vessel due diligence (AIS gaps, ownership trees, insurers, STS history) into payment approval for commodity trades.  

3. Tech / Software
   
   • Enforce geo-blocking, license key controls, telemetry to prevent provision of IT/software to Russia where restricted.  

4. Licenses & GLs
   
   • Maintain a renewal calendar (GL 13O, 8L, etc.). Treat FAQ edits as policy changes requiring new sign-offs and training.  

5. Screening & Data
   
   • Move beyond name-matching: add item-level export checks (BIS “common high-priority items”) and relationship analytics (affiliates, shippers, brokers).  

6. Documentation
   
   • For every Russia-exposed transaction, keep a short memo: parties, goods/services, routes, why allowed (GL/FAQ cite), and the rebuttable red-flags you cleared.

Why Attend This Webinar?

Join this CLE international trade law webinar to gain key insights into OFAC’s expanded enforcement under Executive Order 14114 and its impact on global financial institutions. Learn how to interpret recent licensing updates, manage cross-border risks, and enhance compliance frameworks—all while earning CLE credit.

Strengthen Sanctions Compliance with Confidence!

Join this timely CLE international trade law webinar presented by The Knowledge Group to gain practical insights into OFAC’s expanded enforcement authority and the latest Russia-related measures.

Discover effective strategies to manage cross-border exposure, refine due diligence, and mitigate operational risks. Earn CLE credit while strengthening your ability to navigate the fast-evolving global sanctions landscape with precision and confidence.

Register for this course by clicking the “Take this Course” at the top of the page.