Russia Sanctions Increase in Scale and Scope


Sanctions Package Targets 80 Percent of All Banking Assets in Russia

In a speech, President Joseph R. Biden outlined the latest package of sanctions against the largest Russian banks, among other targets. The White House issued a fact sheet on the details of today's actions, and OFAC provided specifics on targets in both Russia and Belarus. OFAC stated these sanctions go after "the core infrastructure of the Russian financial system" and will impact "nearly 80 percent" of banking assets in Russia.

The White House described today's actions as follows:

This came a day after the U.S. imposed Nord Stream 2 sanctions in response to Russia's full invasion of Ukraine. On February 23, 2022, OFAC added to its SDN list certain individuals and the Nord Stream 2 AG entity and issued General License 4, "Authorizing the Wind Down of Transactions Involving Nord Stream 2 AG."

Earlier in the week, President Biden (i) signed Executive Order ("EO") 14065 blocking trade and most other dealings involving the so-called Donetsk People's Republic or Luhansk People's Republic regions of Ukraine, (ii) added two Russian banks and numerous related entities to its Specially Designated Nationals and Blocked Persons List, and (iii) expanded existing prohibitions on dealings in Russia's sovereign debt. EO 14065 also expanded the scope of the national emergency declared in EO 13660 of March 6, 2014 (see related coverage).

Primary Sources

  1. White House Fact Sheet: Joined by Allies and Partners, the United States Imposes Devastating Costs on Russia

  2. U.S. Treasury Announces Unprecedented & Expansive Sanctions Against Russia, Imposing Swift and Severe Economic Costs

  3. U.S. Treasury Targets Belarusian Support for Russian Invasion of Ukraine

  4. OFAC: PEESA Designations; Issuance of Russia-related General License 4

  5. OFAC: Russia-related General License 4 ,"Authorizing the Wind Down of Transactions Involving Nord Stream 2 AG"

  6. Statement by President Biden on Nord Stream 2

  7. President Joseph R. Biden: Executive Order 14065 on Imposing Blocking Property of Certain Persons and Prohibiting Certain Transactions with Respect to Continued Russian Efforts to Undermine the Sovereignty and Territorial Integrity of Ukraine

NASAA Urges FINRA to Tighten Restrictions on BD Employees Borrowing from Customers

The North American Securities Administrators Association ("NASAA") criticized FINRA's proposed amendment to FINRA Rule 3240 ("Borrowing From or Lending to Customers") on broker-dealers borrowing from or lending to customers.

The proposed amendment would restrict broker-dealer employees entering into borrowing or lending relationships with customers of the broker-dealers. NASAA argued that such credit practices should be banned outright or, if not banned, subject to substantial additional conditions.

Chair Waters Urges Investigation of Housing Discrimination

House Financial Services Committee Chair Maxine Waters (D-CA) urged an investigation into systemic racism "that continue[s] to plague America’s home valuation system, including through home appraisals, despite the passage of anti-discrimination laws."

In a letter to the Department of Housing and Urban Development, National Credit Union Administration, and three appraisal associations, Chair Waters said that her request was prompted by quantitative analysis by Freddie Mac as well as independent research. She also referenced an email by an appraiser which "reveal[s] and perpetuate[s] the false stereotypes upon which racism was founded and continues to shape communities across our country today."

FTC Summarizes ECOA Enforcement Activities

The FTC summarized its enforcement-related activities concerning the Equal Credit Opportunity Act ("ECOA"). The FTC letter was a response to a request by the CFPB which intends to use the information in preparing the CFPB's 2021 Annual Report to Congress.

In the report, the FTC highlighted:

Primary Sources

  1. President Joseph R. Biden: Executive Order 14065 on Imposing Blocking Property of Certain Persons and Prohibiting Certain Transactions with Respect to Continued Russian Efforts to Undermine the Sovereignty and Territorial Integrity of Ukraine

  2. Treasury Bulletin: Issuance of Executive Order Blocking Property of Certain Persons and Prohibiting Certain Transactions with Respect to Continued Russian Efforts to Undermine the Sovereignty and Territorial Integrity of Ukraine

  3. Treasury Press Release: U.S. Treasury Imposes Immediate Economic Costs in Response to Actions in the Donetsk and Luhansk Regions

  4. OFAC: Ukraine General License Number 17

  5. OFAC: Ukraine General License Number 18

  6. OFAC: Ukraine General License Number 19

  7. OFAC: Ukraine General License Number 20

  8. OFAC: Ukraine General License Number 21

  9. OFAC: Ukraine General License Number 22

  10. Treasury Bulletin: OFAC SDN, Consolidated, NS-MBS and SSI List Updates - Russia-Related Designations; Issuance of Russia-Related Directive 1A and General Licenses; Publication of New and Updated Frequently Asked Questions

  11. OFAC: Russia General License 2

  12. OFAC: Russia General License 3

  13. Treasury FAQ 964

  14. Treasury FAQ 965

  15. Treasury: Recently Updated FAQs

  16. Federal Register: Executive Order 13660 Blocking Property of Certain Persons Contributing to the Situation in Ukraine

  17. NASAA Letter regarding Regulatory Notice 21-43: Prohibition on Borrowing from or Lending to Customers

  18. FINRA Regulatory Notice 21-43: Proposed Amendments to FINRA Rule 3240 and Retrospective Rule Review Report

  19. FINRA Rule 3240: Borrowing from or Lending to Customers

  20. FINRA Rule 3241: Registered Person Being Named a Customer's Beneficiary or Holding a Position of Trust for a Customer

  21. House Financial Services Committee Chair Maxine Waters: Letter to Housing Agencies regarding Systematic Racism in the Appraisal Industry

  22. FTC Press Release: FTC Staff Provides Annual Letter to CFPB on 2021 Equal Credit Opportunity Act Activities

  23. FTC Report to CFPB: Equal Credit Opportunity Act in 2021


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National Law Review, Volume XII, Number 55