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Russia Sanctions Now: What Just Changed, What It Means for Your Money Flows, and What To Do Next | Live 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. 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.