On 22 April, OFSI updated its Financial Sanctions FAQs by adding three new Frequently Asked Questions numbers 146 to 148.
FAQs 146-148 concern the designated Russian entities, Rosbank PJSC and Bank Otkritie, that merged with other entities.
OFSI indicated that previously designated Russian bank, Rosbank PJSC, ceased to exist as a separate entity when it merged with TBank on 1 January 2025. Bank Otkritie, which was also designated, ceased to exist as a separate entity upon merging with BM-Bank on 1 January 2025. BM-Bank has been designated due to being owned and controlled by the designated entity, VTB Bank.
Anyone who holds a valid licence referencing either Rosbank or Bank Otkritie and would like to continue relying on such a licence, should request an amendment to this licence from OFSI as soon as possible. Continued use of a licence without the correct licence permissions in place may be viewed as a sanctions breach and could be interpreted as a criminal offence.
When dealing with potentially risky entities, it is important to check their ownership and control structures to ensure sanctions compliance. Ownership and control constitute a complex concept which may require some deep analysis and assessment. Gherson legal experts are ready to assist you with navigating licence and sanctions compliance matters.
How Gherson can assist
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