United States: OFAC Sanctions Potanin, Interros, And Rosbank; But Norilsk Nickel Is Excluded

Today, the Office of Foreign Assets Control ("OFAC") added Russian oligarch Vladimir Potanin along with several of his companies to the Specially Designated Nationals ("SDN") List. OFAC's action specifically targets Mr. Potanin, Interros, an investment holding company controlled by Mr. Potanin, and Rosbank, a major Russian bank owned by Interros. U.S. persons are prohibited from engaging, directly or indirectly, in any transaction or activity involving an SDN, as well as with any entities owned 50 percent or more, directly or indirectly, by one or more SDN(s).

According to OFAC's press release, Mr. Potanin is a close associate of President Vladimir Potanin, and Rosbank has served as an important credit institution for the Government of Russia, helping to fuel the war in Ukraine. Mr. Potanin is also a major shareholder of Norilsk Nickel, one of the world's largest producers of palladium and refined nickel. OFAC confirmed in an FAQ that Norilsk Nickel is not blocked as a result of Mr. Potanin's designation, which is consistent with publicly available information that Mr. Potanin owns less than the 50 percent required to trigger the extension of blocking sanctions on Norilsk Nickel.

Concurrent with Rosbank's designation, OFAC issued General Licenses ("GLs") 58 and 59 that authorize certain wind-down activities until 12:01 AM eastern daylight time, March 15, 2023. GL 58 authorizes transactions ordinarily incident and necessary to exit operations, contracts, or other agreements involving Rosbank or entities owned 50 percent or more, directly or indirectly, by Rosbank (collectively, "Rosbank entities"). GL 58 also authorizes U.S. financial institutions to reject, rather than block, all transactions ordinarily incident and necessary to the processing of funds involving Rosbank entities, as well as for individuals to close their accounts. GL 59 authorizes U.S. persons to divest or transfer securities in Rosbank entities during the wind-down period.

OFAC also added 17 subsidiaries of VTB Bank Public Joint Stock Company, Russia's second largest bank, to the SDN List as part of this action, among other individuals and entities.

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