A large international company has established a legal entity in the Russian Federation. Subsequently, the company had a question related to the fact that the bank, whose services are used by a Russian legal entity, is on the US sanctions lists, or rather, on the sectoral sanctions list of the US Treasury Department's Office of Foreign Assets Control (hereinafter referred to as the Office). The refusal to cooperate with this bank could affect the entire international structure of the corporation and make adjustments to the company's activities (not only in the Russian Federation) with possible negative consequences.

Due to the need to continue working with this particular credit institution, the client asked BBNP specialists to analyze the bank's sanctions regime and possible risks if cooperation continues.

BBNP lawyers studied US government regulations on relevant topics and the practice of their application in terms of influencing individuals who interact in one way or another with sanctioned organizations.

The entities that are obliged to comply with these rules have been identified, and the prohibitive provisions themselves have been identified, identifying specific acts that the Office considers to be violations of sanctions acts.

Our experts identified the scope of powers of government agencies, the possible consequences for a Russian legal entity and other members of an international group of companies when qualifying the client's actions as violating these norms, and legally justified the client's ability to work with this bank.

After receiving a detailed consultation, the company's representatives, confident that there were no risks, decided to continue profitable cooperation with the credit institution.

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