Russia Sanctions Now: What Changed & What To Do | On-Demand CLE International Trade Law Webinar

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

Broadcast Date: Thursday, October 30, 2025, from 12:00 PM to 1:00 PM (ET)

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.

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).
• OFAC advisory & FAQs (June 2024–June 2025.
• Action items.
  
  • Map FFI exposure
  • Narrative memos for each at-risk transaction (who/what/why allowed).

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.
• Licensing/waiver example: NIS (Serbia) waiver to Oct 8, 2025.
• 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.

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.
• GL 8L (Jan 10, 2025) wind-down authority
• Practical takeaway: build a “GL tracker,” treat FAQ edits as change-management events.

4) Enforcement trends—what OFAC is signaling

• Settlements continue (e.g., ShapeShift AG, Sept 23, 2025). Crypto ≠ 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.

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, 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.