美国OFAC大幅制裁俄罗斯金融业
- Boring Editor
- 2024年11月22日
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2024年11月21日
美国财政部外国资产管制办公室（OFAC）在执行七国集团领导人做出的承诺方面又迈出了重要一步，即减少俄罗斯使用国际金融体系以推进对乌克兰冲突。外国资产管制处的行动包括指定俄罗斯天然气工业银行、50多家国际联系的俄罗斯银行、40多家俄罗斯证券注册机构和15名俄罗斯金融官员。外国资产管制處还发布了一个警报，描述了与俄罗斯金融信息传输系统（SPFS）相关的制裁风险，克里姆林宫创建并用于规避制裁。
俄罗斯天然气工业银行香港下属GPB Financial Services Hong Kong Limited也受到制裁。本次受制裁主体将次级制裁约束。
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GAZPROMBANK
OFAC is designating Gazprombank Joint Stock Company (Gazprombank) alongside its six foreign subsidiaries. Gazprombank is a conduit for Russia to purchase military materiel for its war effort against Ukraine. The Russian government also uses Gazprombank to pay its soldiers, including for combat bonuses, and to compensate the families of Russian soldiers killed fighting Putin’s brutal war against Ukraine. Australia, Canada, New Zealand, and the United Kingdom have previously sanctioned Gazprombank.
Luxembourg-based bank GPB International SA, Hong Kong-based GPB Financial Services Hong Kong Limited, Cyprus-based GPB Financial Services Limited and GPB-DI Holdings Limited, Switzerland-based Gazprombank (Switzerland) Ltd, and South Africa-based GPB Africa and Middle East Pty Ltd are wholly owned subsidiaries of Gazprombank.
Gazprombank is being designated pursuant to Executive Order (E.O.) 14024 for operating or having operated in the financial services sector of the Russian Federation economy. GPB International SA, GPB Financial Services Hong Kong Limited, GPB Financial Services Limited, GPB-DI Holdings Limited, Gazprombank (Switzerland) Ltd, and GPB Africa and Middle East Pty Ltd are being designated pursuant to E.O. 14024 for being owned or controlled by, or for having acted or purported to act for or on behalf of, directly or indirectly, Gazprombank. All entities owned 50 percent or more, directly or indirectly, by Gazprombank or the six designated Gazprombank subsidiaries, are subject to blocking, even if not identified by OFAC.
Concurrently with this action, OFAC is issuing two new general licenses (GL) authorizing U.S. persons to wind down transactions involving Gazprombank, among other financial institutions, and to take the necessary steps to divest from debt or equity issued by Gazprombank. OFAC is also amending Russia-related GL 53 to ensure that diplomatic banking activities involving Gazprombank are not disrupted. OFAC continues to maintain a variety of authorizations, including GLs authorizing transactions related to agricultural commodities, medicine, medical devices, certain transactions in support of non-governmental organizations, the official business of third-country diplomatic missions located in the Russian Federation, and certain transactions and official business of certain international organizations and entities.
ANNEX 1: DOZENS OF RUSSIAN BANKS
The following Russia-based financial institutions and individual are being designated pursuant to E.O. 14024 for operating or having operated in the financial services sector of the Russian Federation economy:
Aktsionernoe Obshchestvo Bank Agroros is a bank headquartered in Saratov, Russia.
Bank Iturup LLC is a bank headquartered in Yuzhno-Sakhalinsk, Russia.
BBR Bank Joint Stock Company is a bank headquartered in Moscow, Russia.
BCS Bank AO is a bank headquartered in Moscow, Russia.
Bratsky Narodny Bank JSC is a bank headquartered in Bratsk, Russia.
Centrocredit Bank is a bank headquartered in Moscow, Russia.
Commercial Bank Energotransbank Joint Stock Company is a bank headquartered in Kaliningrad, Russia.
Commercial Bank Khlynov Joint Stock Company is a bank headquartered in Kirov, Russia.
Commercial Bank Kremlyovskiy is a bank headquartered in Moscow, Russia.
Commercial Joint Stock Bank Viking is a bank headquartered in Saint Petersburg, Russia.
Corporate Finance Bank LLC is a bank headquartered in Moscow, Russia.
Evrofinance Mosnarbank is a bank headquartered in Moscow, Russia. Evrofinance Mosnarbank was previously designated pursuant to E.O. 13850.
Fora Bank Joint Stock Commercial Bank is a bank headquartered in Moscow, Russia.
Garant Invest Bank Joint Stock is a bank headquartered in Moscow, Russia.
Interstate Bank is a bank headquartered in Moscow, Russia.
Joint Stock Commercial Bank National Reserve Bank Joint Stock Company (NRB)is a bank headquartered in Moscow, Russia. Daniel Haindl (Haindl) is the Senior Vice President of NRB. In his role at NRB, Haindl has been involved in a sanctions evasion scheme.
Joint Stock Commercial Bank Slavia Joint Stock Company is a bank headquartered in Moscow, Russia.
Joint Stock Commercial Mortgage Bank Akibank Public Joint Stock Company is a bank headquartered in Naberezhnye Chelny, Russia.
Joint Stock Company Auto Finance Bank is a bank headquartered in Moscow, Russia.
Joint Stock Company Bank Accept is a bank headquartered in Novosibirsk, Russia.
Joint Stock Company Bank Dom RF is a bank headquartered in Moscow, Russia.
Joint Stock Company Bank Finservice is a bank headquartered in Moscow, Russia.
Joint Stock Company Bank United Capital is a bank headquartered in Saint Petersburg, Russia.
Joint Stock Company Coalmetbank is a bank headquartered in Chelyabinsk, Russia.
Joint Stock Company Commercial Bank Ural FD is a bank headquartered in Perm, Russia.
Joint Stock Company Guta Bank is a bank headquartered in Moscow, Russia.
Joint Stock Company NS Bank is a bank headquartered in Moscow, Russia.
Joint Stock Company Public Trust Bank is a bank headquartered in Moscow, Russia.
Joint Stock Company Royal Credit Bank is a bank headquartered in Vladivostok, Russia.
Joint Stock Company Severgazbank is a bank headquartered in Vologda, Russia.
Joint Stock Investment Commercial Bank Eniseisk United Bank is a bank headquartered in Krasnoyarsk, Russia.
JSC Exi Bank is a bank headquartered in Saint Petersburg, Russia.
JSCB Energobank is a bank headquartered in Kazan, Russia.
Kamsky Commercial Bank is a bank headquartered in Naberezhnye Chelny, Russia.
Limited Liability Company Bank Orange is a bank headquartered in Saint Petersburg, Russia.
Limited Liability Company Bank Round is a bank headquartered in Moscow, Russia.
Limited Liability Company Krona Bank is a bank headquartered in Irkutsk, Russia.
MB Bank is a bank headquartered in Moscow, Russia.MB Bank, also known as Mir Business Bank, is the Russia-based wholly-owned subsidiary of Iran’s Bank Melli Iran. MB Bank was previously designated previously designated pursuant to E.O. 13224 and E.O. 13582.
National Standard Bank Joint Stock Company is a bank headquartered in Moscow, Russia.
New Moscow Bank is a bank headquartered in Moscow, Russia.
NK Bank Joint Stock Company is a bank headquartered in Moscow, Russia.
Primorsky Territorial Commercial Bank Society with Limited Liability is a bank headquartered in Vladivostok, Russia.
Public Joint Stock Commercial Bank Derzhava is a bank headquartered in Moscow, Russia.
Public Joint Stock Company Bank Alexandrovsky is a bank headquartered in Saint Petersburg, Russia.
Public Joint Stock Company Bank Sinara is a bank headquartered in Yekaterinburg, Russia.
Public Joint Stock Company Finstar Bank is a bank headquartered in Saint Petersburg, Russia.
Public Joint Stock Company Metkombank is a bank headquartered in Kamensk-Uralskiy, Russia.
Public Joint Stock Company National Bank Trust is a bank headquartered in Moscow, Russia.
Public Joint Stock Social Commercial Bank of Primorye Primsotsbank is a bank headquartered in Vladivostok, Russia.
Rossita Bank is a bank headquartered in Moscow, Russia.
Russian Public Joint Stock Commercial Roads Bank is a bank headquartered in Moscow, Russia.
Russian Universal Bank is a bank located in Moscow, Russia.
Vitabank PJSC is a bank headquartered in Podolsk, Russia.
Waybank JSC is a bank headquartered in Moscow, Russia.
ANNEX 2: RUSSIAN SECURITIES REGISTRARS
The following Russia-based financial institutions function as registrars and are being designated pursuant to E.O. 14024 for operating or having operated in the financial services sector of the Russian Federation economy:
Aktsionernoe Obshchestvo Agentstvo Regionalnyi Nezavisimyi Registrator is a registrar based in Tula, Russia, and Lipetsk, Russia.
Aktsionernoe Obshchestvo Mezhregionalnyi Registratorskii Tsentr is a registrar based in Moscow, Russia.
Aktsionernoe Obshchestvo Natsionalnaya Spetsializirovannaya Finansovaya Kompaniyais a registrar based in Novosibirsk, Russia.
Aktsionernoe Obshchestvo Nezavisimaya Registratorskaya Kompaniya R.O.S.T. is a registrar based in Moscow, Russia.
Aktsionernoe Obshchestvo Professionalnyi Registratsionnyi Tsentr is a registrar based in Moscow, Russia.
Aktsionernoe Obshchestvo Registrator Kapitalis a registrar based in Yekaterinburg, Russia.
Aktsionernoe Obshchestvo Spetsializirovannyi Registrator Kompas is a registrar based in Novokuznetsk, Russia.
Aktsionernoe Obshchestvo Surgutinvestneft is a registrar based in Surgut, Russia.
Aktsionernoe Obshchestvo Vedenie Reestrov Kompanii is a registrar based in Yekaterinburg, Russia.
Aktsionernoe Obshchestvo Independent Specialized Depository is a registrar based in Moscow, Russia.
AO Reestr is a registrar based in Moscow, Russia.
Aktsionernoe Obshchestvo Registratsionnaya Kompaniya Tsentr Invest is a registrar based in Irkutsk, Russia, and Moscow, Russia.
Aktsionernoe Obshchestvo Depozitarnaya Kompaniya Region is a registrar based in Moscow, Russia.
Evroaziatskii Registrator is a registrar based in Kazan, Russia.
AO Spetsializirovannyi Depozitarii Infinitum is a registrar based in Moscow, Russia.
Joint Stock Company Aktiv is a registrar based in Saint Petersburg, Russia.
Joint Stock Company Industria Reestr is a registrar based in Moscow, Russia.
Joint Stock Company RDC Paritet is a registrar based in Moscow, Russia.
Joint Stock Company Registrator Intraco is a registrar based in Perm, Russia.
Joint Stock Company Registry Society Status is a registrar based in Moscow, Russia.
JSC DRAGA is a registrar based in Moscow, Russia, and Saint Petersburg, Russia.
JSC Republican Specialregistrar Yakut Fund Center is a registrar based in Yakutsk, Russia.
JSC RT Registrar is a registrar based in Moscow, Russia.
JSC Service Reestr is a registrar based in Moscow, Russia.
JSC Noviy Registrator is a registrar based in Moscow, Russia.
Korporativnaya Registratorskaya Kompaniyais a registrar based in Moscow, Russia.
Limited Liability Company Depositary and Corporate Technologies is a registrar based in Moscow, Russia.
Limited Liability Company Special Depository Partner is a registrar based in Moscow, Russia.
Limited Liability Company Specialized Depository Company Garant is a registrar based in Moscow, Russia.
Moskovskii Fondovyi Tsentr is a registrar based in Moscow, Russia.
National Custodial Company Stock Closed Corporation is a registrar based in Moscow, Russia.
Obshchestvo S Ogranichennoy Otvetsvennostyu Oboronregistr is a registrar based in Moscow, Russia.
OOO Partner is a registrar based in Cherepovets, Russia.
OOO Reestr RN is a registrar based in Moscow, Russia.
OOO Registrator Garant is a registrar based in Moscow, Russia.
Registrator KRTS is a registrar based in Krasnodar, Russia.
Spetsializirovannyi Depozitarii Depo Plaza is a registrar based in Moscow, Russia.
Spetsializirovannyi Registrator Rekom is a registrar based in Staryy Oskol, Russia.
Tsentr Ucheta i Registratsii is a registrar based in Saint Petersburg, Russia.
Yuzhno Regionalnyi Registrator is a registrar based in Rostov-na-Donu, Russia.
Zakrytoe Aktsionernoe Obshchestvo Pervyi Spetsializirovannyi Depozitarii is a registrar based in Moscow, Russia.
ANNEX 3: CBR OFFICIALS
The following Russian nationals are officials at the Central Bank of the Russian Federation (CBR), which is subject to Directives 1 and 4 of E.O. 14024, and are being designated pursuant to E.O. 14024 for operating or having operated in the financial services sector of the Russian Federation economy:
Alla Bakina (Bakina) is the Director of the National Payment System Department of the CBR and is responsible for modernizing CBR payment systems. Bakina is involved in expanding the reach of Russia’s System for Transfer of Financial Messages (SPFS) and Faster Payments System (SBP).
Vladimir Chistyukhin has been a First Deputy Governor of the CBR since 2022 and a Member of the Board of Directors of the CBR since 2023.
Elizaveta Danilova is Director of the Financial Stability Department at the CBR and has been a Member of the Board of Directors of the CBR since 2023.
Gulnara Khaidarshina is the Director of the Department for Cooperation with International Organizations at the CBR.
Mikhail Anatolyevich Kovrigin is the Director of the International Settlements Department at the CBR.
Ekaterina Lozgacheva has been the Director of the Financial Market Strategy Department of the CBR since 2023 and previously served in other positions at the CBR dating back to 2011.
Alexandr Morozov has been the Director of the Research and Forecasting Department at the CBR since 2015.
Olga Vasilyevna Polyakova has been a Deputy Governor of the CBR since 2016 and a Member of the Board of Directors of the CBR since 2021.
Kirill Pronin (Pronin) is the Director of the Financial Market Infrastructure at the CBR. Pronin was previously Director of the CBR’s Department of Financial Technologies.
Bogdan Shablya is head of the CBR’s Financial Monitoring and Currency Control Department and has worked at the CBR for more than 25 years.
Dmitry Tulin is a First Deputy Governor of the CBR and has been a Member of the Board of Directors of the CBR since 2020.
https://ofac.treasury.gov/recent-actions/20241121