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As of February 24th, , 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) has imposed further sanctions. https://home.treasury.gov/system/files/126/20230302_compliance_note.pdf  The newest sanctions continue to go after the banking industry to limit the movement of money to and from Russia through traditional payment processes.

OFAC Sanctions imposed on Russia are at the level of individual names, parties, companies and organizations.  https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/russia-related-sanctions

The sanctions were designed focusing on third party buyers and countries.  Diverting a shipment via a buyer, party or organization not on the sanctions list will place your company at risk for breaking the sanctions.

If the buyer is a third party and there is an intent to ship to Russia, the product must be screened against the OFAC sanctions,  BIS compliance regulations and  DDTC compliance regulations.

There are many general licenses available for trade with Russia. Specific licenses from OFAC may be applied for through the OFAC License application page. If you are in a business that is falling under general licenses or special license and you are running into problems collecting money from Russia due to the sanctions, you can report your issues to The Office of Foreign Asset Control (OFAC) for assistance. There are special licenses that can be requested for money movement.  If authorized, this will open up a money corridor for payments.   It is very important to request the assistance of OFAC and not try to figure it out on you own.  https://home.treasury.gov/policy-issues/financial-sanctions/ofac-license-application-page

BDG International helps companies to stay in compliance and assist in proper way to export. If you have any questions, please contact Lisa Waller [email protected] for further assistance.