If Russia goes ahead with an invasion of the Ukraine, the United States sanctions will definitely include that country's most prominent financial institutions. Public statements made by a bipartisan committee of United States Senators this week have confirmed that the sanctions proposed, which have already included massive measures by OFAC, The Office of Foreign Assets Control, and removal from the SWIFT international payments system, include Russian banks.
Some of the banks named include:
RUSSIAN DIRECT INVESTMENT FUND
Reports, based upon additional interviews with American government officials, also include a total banning of Russia from the American financial structure, as presently exists with respect to North Korea and other State Sponsors of Terrorism. These extreme measures would definitely impact banks in the European Union that routinely conduct funds transfers with Russian banks, for Russian clients, individuals and corporate entities, whether they be US Dollar transactions, or in other currencies.
EU compliance officers at international banks should now immediately ascertain what ongoing transactions they have with any Russian financial institutions, especially involving energy companies and high-tech entities, as those sectors have been specifically named as targets of immediate sanctions when the shooting starts on the Ukraine frontier with Russia, and make contingencies to freeze them forthwith. To do otherwise risks the wrath of the US Department of the Treasury.