Tracking Financial Sanctions Against Russia...and What They Mean for U.S. Banks and Other Financial Institutions

By RMA

2/22/2022

Russia's military invasion of Ukraine has rattled global markets and threatened decades of fragile peace in Europe. The United States and European allies have systematically responded with precise sanctions meant to punish Russian banks and wealthy backers of Russian President Vladimir Putin. How is this crisis impacting banks and other financial institutions? Please visit our Russia Banking Sanctions content hub for RMA's latest news updates and webinars on this topic.

On Monday, Russia defaulted on its foreign debt for the first time since 1918, after missing payments on two foreign-currency bonds on Sunday.

According to the Wall Street Journal, Monday “marks the expiration of a 30-day grace period since the country was due to pay the equivalent of $100 million in dollars and euros to bondholders.”

Switzerland announced Friday it had adopted new EU sanctions against Belarus and Russia, as the Federal Council also imposed new financial and travel sanctions on 100 individuals and entities, including oligarch Aleksandra Melnichenko.

As part of the European Union’s sixth round of sanctions against Russia, Russia's biggest bank Sberbank will be removed from the global SWIFT messaging system.

The sanctions, announced Friday, June 3, also ban most Russian oil imports, prohibit accounting, auditing and consultancy services to Russian entities, and adds to the ever-expanding list of blacklisted f Russian individuals.

European Union leaders are meeting in Brussels Monday and Tuesday to finalize details of a sixth round of sanctions against Russia.

On Monday night, a possible breakthrough was reached with regards to enacting an oil embargo against Russia. According to The Wall Street Journal, "The embargo would include an exemption for oil delivered from Russia via pipelines, an amount that makes up one-third of EU oil purchases from Russia. EU officials said that by the end of this year, the embargo would cover 90% of previous Russian oil imports."

This exemption would placate Hungary, which relies heavily on Russian oil. Hungarian Prime Minister Viktor Orban said the proposal "is a good approach."

Ukrainian President Volodymyr Zelensky spoke at the 2022 World Economic Forum Monday, May 23, and advocated for “maximum” sanctions against Russia.

“This is what sanctions should be: They should be maximum, so that Russia and every other potential aggressor that wants to wage a brutal war against its neighbor would clearly know the immediate consequences of their actions,” Zelensky said, according to Marketwatch.

“I believe there are still no such sanctions against Russia," Zelensky said. "There should be a Russian oil embargo. Russian banks should be banned, no exception. There should be an abandonment of the Russian IT sector. There should not be any trade with Russia."

In an interview published Tuesday, Germany's finance minister said he supported financing the rebuilding of Ukraine by seizing Russian state interviews.

"I am politically open to the idea of seizing foreign assets of the Russian Central Bank," said Christian Lindner in an interview with Handelsblatt. "In the case of private assets, we have to see what is legally possible. We have to respect the rule of law, even if we are dealing with Russian oligarchs."

The United States announced a new round of sanctions Sunday, targeting banking executives from Sberbank, Russia’s largest lender, and Gazprombank, the primary bank for Russian energy company Gazprom.

According to the Wall Street Journal, the sanctions also “will seek to clamp down on advertising dollars flowing into three Russian television stations, bar U.S. consulting firms from providing services to Russian companies seeking to evade sanctions and limit Russia’s access to industrial engines, motors and bulldozers.”

Sberbank, Russia's largest lender, could be removed from SWIFT as part of the latest round of European sanctions.

Reuters reports that the E.U.'s executive Commission proposed on Wednesday to cut Sberbank and two other Russian banks – “named by two EU sources as Credit Bank of Moscow and the Russian Agricultural Bank from SWIFT.”

SWIFT, the Society for Worldwide Interbank Financial Telecommunication, is a messaging system that connects about 11,000 banks in 200 countries and territories, with almost 4,400 banks in the U.S. on the platform. (Read: What is SWIFT and its Role in Global Banking?)

On Friday, April 29, Russia’s central bank cut its key interest rate for the second time this month as the country addresses steep inflation following crippling sanctions.

According to the Wall Street Journal, “The Bank of Russia lowered its key interest rate to 14% from 17%, having already cut borrowing costs from 20% on April 8. Policy makers led by central bank chief Elvira Nabiullina, doubled the key rate in an emergency meeting on Feb. 28 as they scrambled to support the ruble after Western governments froze almost half of the country’s foreign exchange reserves.”

The Wall Street Journal reported Monday that Société Générale is selling its stake in Russian Bank Rosbank to Interros, an investment run by metals billionaire Vladimir Potanin.

According to the Wall Street Journal, "Société Générale said the exit would result in hits to its capital and income, including an estimated $3.4 billion it said would be accounted for in its income statement. The Russian business accounted for less than 3% of Société Générale’s 2021 earnings, and the bank said it remains committed to paying dividends and buying back shares."

The United States announced a new round of sanctions Wednesday, targeting Russian banks and family members of the country’s leadership, in response to what the White House called "major war crimes."

The new sanctions target Russia's Sberbank and Alfabank, the country's second and fourth largest financial institutions, respectively.

Reuters noted that the full blocking sanctions “will freeze Sberbank and Alfabank's assets ‘touching the U.S financial system,’ the White House said. Britain also froze Sberbank's assets, and said it would ban imports of Russian coal by the end of this year as part of a coordinated allied effort to ‘starve Putin's war machine.’”

Russia said Wednesday it sent $650 million in bond payments on dollar bonds in rubles to the National Settlement Depository.

Russia's Finance Ministry said it believes its obligations "have been fulfilled in full." after foreign banks had refused to process the payment, which was due Monday, in dollars.

According to Business Insider, “ratings agencies have said they would consider Russia to have technically defaulted if it resorted to paying dollar-denominated debts in rubles. Credit ratings agency Fitch said in March that a ‘forced redenomination of payment obligations’ would indicate "that a default or default-like process has begun." Fitch has since withdrawn all Russian ratings.”

The payments were for bonds maturing this month and for a coupon on notes due April 2042. As Bloomberg notes, “neither security allowed Russia the option to pay in rubles, according to bond documents, raising investor concern that the country is at risk of a default. Both notes have a 30-day grace period, data compiled by Bloomberg show.”

The U.S. and E.U. are expected Wednesday to announce new sanctions targeting Russian banks, Russian coal, and possibly President Putin’s family.

Related sanctions news for Wednesday, April 6:

Yellen to Warn of Economic Repercussions from Ukraine Invasion (New York Times)
S., Allies Ready New Russian Sanctions After Bucha Killings (International Business Times)
VTB Bank to Seek Administration for U.K. Unit After Sanctions (Bloomberg)

On Tuesday, the U.S. Treasury announced it had halted dollar debt payments from Russian government accounts at U.S. banks.

As Fortune noted, “The move is designed to force Russia into choosing among three unappealing options — draining dollar reserves held in its own country, spending new revenue, or going into default, said a spokesperson for the Treasury’s Office of Foreign Assets Control who discussed details of the decision on condition of anonymity.”

In mid-March, Russia was up against a March 16 deadline to pay $117 million in interest on two dollar-denominated bonds. But on March 17, the Russia's government said the debt payment was made in a foreign currency, without revealing which currency.

On Tuesday, Andrey Kostin, CEO of No.2 lender VTB, said that Russian banks would need more recapitalization.

According to Reuters, Kostin said Tuesday, "I don't know yet where the capital boost will come from but it will come for sure. Not only for VTB but for the wider banking sector, I think." Kostin also said he expected the financial sector to post losses this year.

Related sanctions news for Tuesday, April 5:

On Monday, April 4, JPMorgan chief executive Jamie Dimon highlighted the array of risks facing the U.S. economy in his annual shareholders letter, citing inflation, rising interest rates, the lingering pandemic, and Russia’s invasion of Ukraine as factors that challenge global markets.

"While it is possible, and hopeful, that all of these events will have peaceful resolutions, we should prepare for the potential negative outcomes,” Dimon wrote.

Dimon specifically acknowledged global sanctions against Russia "at a minimum, will slow the global economy — and it could easily get worse."

"Along with the unpredictability of war itself and the uncertainty surrounding global commodity supply chains, this makes for a potentially explosive situation," Dimon added.

Related sanctions news for Monday, April 4:

Secondary Sanctions: Unilateral Escalation by U.S. Would Lack Punch (FT)
Deutsche Bank CEO Sees German Recession if Russian Gas Cut Off (Bloomberg)
Russia's Largest Bank Silently Rolled Out Native Cryptocurrency Sbercoin (International Business Times)

European Union officials are considering new bank sanctions, according to the Wall Street Journal.

WSJ reports that EU officials are discussing “how to deploy the bloc’s anti-money-laundering blacklist against countries found to be helping circumvent Western sanctions. Those discussions include whether to place Russia on the EU blacklist, although officials say no decision is imminent on that.”

During an interview with Bloomberg TV Tuesday, UBS Group AG outgoing Chairman Axel Weber said that he sees no future for many international banks in Russia.

“I personally, and this is for my successors to decide, do not see any future of business onshore in Russia for many of the international banks,” said Weber. “Even if we come to a cease-fire, Russia has put itself outside the international community and this will have a pretty long-dated consequence.”

Bloomberg reports that Credit Suisse Group AG has stopped pursuing new business in Russia and is helping its clients unwind their Russia exposure.

On March 15, Credit Suisse Chief Executive Officer Thomas Gottstein had said the bank was reviewing its exposure to Russia but for now, was remaining in the country. ““We will have to see now over the next few months what this all means for our operation in Russia,” Gottstein said. “I have not taken any decisions on that.”

But on Monday, the bank confirmed it has moved roles out of the country and is assisting employees to relocate elsewhere.

International sanctions targeting banks, companies, and oligarchs have crippled Russia’s economy. But as Russia’s military invasion into Ukraine enters a second month, the United States and other nations may look to impose secondary sanctions on countries that may be serving as a “safe haven” for Russia’s business interests.

Reuters reports Turkey may be the most prominent at-risk country to secondary sanctions. Over 14,000 individuals have fled to Turkey since the war began and the country has announced it will not, for now, impose any sanctions on Russia.

"If the humanitarian tragedy persists and Putin has no intention of backing down, I think secondary sanctions are inevitable," Hakan Akbas, founding partner of Istanbul-based Strategic Advisory Services, which deals with sanctions, said in an interview with Reuters.

The Treasury Department’s Office of Foreign Assets Control announced new sanctions which specifically target the CEO of Sberbank, as well as Russian defense companies and 328 members of the Russian State Duma.

The U.S. Treasury also issued a notice that gold transactions with Russia are prohibited.

“U.S. persons are prohibited from engaging in any transaction -- including gold-related transactions -- involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation or the Ministry of Finance of the Russian Federation,” the Treasury announced in a statement.

The International Business Times reports that Citigroup Inc, JPMorgan Chase & Co, Societe Generale and other international banks are being pressured to remain as custodian banks in Russia, as rivals and funds worry they may lose services critical to future investment in the country.

According to IBT, "Citigroup and SocGen, the French parent of Rosbank, have already announced plans to dramatically pare operations in Moscow as part of a sweeping program of Western sanctions aimed at isolating Russia economically following its invasion of Ukraine."

European Central Bank President Christine Lagarde said Tuesday that Russian individuals and corporations are leveraging cryptocurrencies to evade Western sanctions.

According to Business Insider, Lagarde said at a conference Tuesday that cryptocurrencies, "are certainly being used, as we speak, as a way to circumvent the sanctions that have been decided by many countries around the world against Russia and a specific number or players."

The Biden White House warned U.S. companies to bolster cybersecurity defenses, based on new intelligence that the Russian Government is preparing for potential cyberattacks.

During a press conference Monday, Anne Neuberger, U.S., deputy national security advisor for cyber and emerging technology, would not identify specific industries possibly being targeted for cyber attacks. However, Neuberger did say “There is some preparatory activity that we’re seeing.”

The Wall Street Journal noted Tuesday that artificial-intelligence models, which handle everything from risk modeling to lending at financial institutions, are especially vulnerable to cyber attacks, writing “Unlike the efforts to gird systems against ransomware attacks, the protection of machine learning remains in its infancy, putting the institutions that use them at considerable risk.”

Italy's second largest bank UniCredit is encountering delays in the sale of its stake of Russia's Alfa Bank, due to international sanctions.

According to Bloomberg, "UniCredit in November exercised an option to sell its 10% in ABH Holdings, the owner of Alfa-Bank, expecting the deal to close by March, according to filings. But the sale may not be finalized in time after the European Union and the U.S. imposed sanctions on Alfa-Bank following Russia’s invasion of Ukraine."

The Russian government may have avoided defaulting on its debt Thursday. Russia was up against a March 16 deadline to pay $117 million in interest on two dollar-denominated bonds. According to Bloomberg, “JPMorgan Chase & Co. has processed funds that were earmarked for interest payments due on dollar bonds issued by the Russian government and sent the money on to Citigroup Inc.”

And on Friday, The Central Bank of Russia maintained its key interest rate at 20%, saying in a statement, “The Bank of Russia’s monetary policy is set to enable a gradual adaptation of the economy to new conditions and a return of annual inflation to 4% in 2024.”

The CEO of Raiffeisen Bank International AG said Thursday his bank is considering an exit from Russia.

Raiffeisen is the largest foreign-owned retail bank in Russia. Two weeks ago, Chief Executive Officer Johann Strobl announced the bank had no plans to wind down Russia operations. But in a statement Thursday, Stobl said the bank is "assessing all strategic options for the future of Raiffeisenbank Russia, up to and including a carefully managed exit from Raiffeisenbank in Russia.”

A fresh round of sanctions from both the European Union and the U.K. were announced Tuesday, March 15.

The U.K. added more than 370 names to their sanctions list. New additions include Mikhail Fridman, founder of Alfa Bank, Russia’s largest private bank, and his business partners German Khan and Petr Aven.

Fridman was one of the first and one of the few Russian oligarchs to release a statement against Russia's invasion of Ukraine. According to the Financial Times, in a February 27 letter to his staff, Fridman wrote, "I am a businessman with responsibilities to my many thousands of employees in Russia and Ukraine. I am convinced however that war can never be the answer. This crisis will cost lives and damage two nations who have been brothers for hundreds of years.”

Citigroup said Monday it would accelerate its plans to sell its Russia consumer division. In a short statement, Citigroup announced it had “now decided to expand the scope of that exit process to include other lines of business and continue to reduce our remaining operations and exposure.”

Meanwhile, at a Morgan Stanley conference Tuesday, Credit Suisse Group AG Chief Executive Officer Thomas Gottstein said the bank is reviewing its exposure to Russia but for now, is remaining in the country.

The CEO of Italy’s second largest bank, UniCredit is reportedly also considering an exit from Russia.

On Sunday, financial regulators in The Bahamas ordered the country’s financial institutions to halt all transactions with Russian and Belarusian entities that have been put under sanction by Western nations, according to Reuters.

Bermuda’s aviation regulator also said over the weekend it was suspending permits for Russian-operated planes over safety oversight concerns. The move could ground 745 plans.

Singapore’s central bank also announced sanctions against Russia. Bloomberg reports that, besides targeting banks and other financial institutions, the Monetary Authority of Singapore also announced that, “digital payment token service providers are prohibited from facilitating transactions that could aid the circumvention of the financial measures.”

After Citigroup announced Wednesday it was reviewing its Russia operations, Goldman Sachs and JPMorgan Chase announced they would both be exiting the country.

And on Friday, Bloomberg reported that Japan’s top lenders, including the banking unit of Mitsubishi UFJ Financial Group Inc., “Are pulling their Japanese staff out of Russia due to safety concerns following its invasion of Ukraine.”

In a statement Wednesday evening, Citigroup revealed steps the bank was taking to address the humanitarian crisis in Ukraine.

Edward Skyler, Executive Vice President, Global Public Affairs, announced Citigroup was providing $1 million in donations from the bank’s foundation to relief organizations. Kyler also said, “We will match contributions from Citi colleagues, which could lead to an additional $500,000 in donations.”

Skyler also provided an update on Citi’s efforts to exit Russia.

The European Union is set to announce a new round of sanctions on Wednesday, March 9, targeting Russia’s National Wealth Fund, as well as 14 wealthy individuals and more than 140 members of the upper house of the Russian Parliament.

The new sanctions would also remove three Belarus banks from the SWIFT international payments system.

Bloomberg reported that “the measures were approved by EU ambassadors and will be adopted by the Council of the EU shortly, according to a tweet on Wednesday by the French representation to the EU.”

However, the latest round of sanctions may spare Russia’s Sberbank bank’s removal from the SWIFT messaging system. According to Bloomberg, Germany continues to resist efforts to cut Sberbank from SWIFT.

The U.S. warned financial institutions to be alert for Russian sanctions evasion attempts. According to Reuters:

"The Financial Crimes Enforcement Network (FinCEN) issued an alert on Monday advising all financial institutions to be vigilant and laying out examples of red flags that it said would help identify sanctions evasion activity, including the use of shell companies.”

The FinCEN alert also warned of possible ransomware attacks, and recommended financial institutions report any suspicious activity and conduct risk-based customer due diligence.

Freshfields Bruckhaus Deringer announced Monday that the law firm was dropping VTB Bank as a client. Another law firm, Norton Rose Fulbright, said it would no longer take new business from the Russian bank and was considering severing ties as well.

Freshfields had represented VTB Bank in a lawsuit just last week. But on Monday, the firm said in a statement that it condemned the actions of the Russian government and "expresses our solidarity with all those affected. This approach goes beyond what is required to comply with our legal, regulatory and professional obligations, and reflects our values as a firm and the wider responsibilities of the global business community."

Over the weekend, the Financial Times reported that VTB Bank, Russia's second largest banks by asset size, may be winding down its European operations. And British Members of Parliament were urging major banks to shut their Moscow offices.

On Friday, the European Union's top diplomat said all options are on the table as the E.U. considers another round of sanctions against Russia.

According to the Global Banking & Finance Review, Ireland’s Foreign Minister Simon Coveney said "A fourth round of sanctions could affect more Russian banks’ access to the SWIFT international transfer system, bar Russian ships from European ports and cut imports from Russia."

The European Union is considering removing banks in Belarus from the SWIFT messaging system, according to a Reuters reports on Thursday, March 3. Reuters is also reporting that EU regulators are preparing for a possible closure of VTB in Europe.

The Austrian operations of Sberbank will go into insolvency, the EU’s Single Resolution Board announced Tuesday night, March 1. And the Croatian and Slovenian units of Russia's biggest lender are being transferred to new owners. The Board announced that "Eligible deposits up to €100,000 are protected by the Austrian deposit guarantee system."

Japan's Prime Minister Fumio Kishida announced sanctions against Russia's central bank. Japan will also impose sanctions on financial institutions in Belarus, and individuals, including President Alexander Lukashenko.

Elvira Nabiullina, the governor of the Bank of Russia said in a statement that, as a result of international sanctions, “The conditions for the Russian economy have altered dramatically. The banking sector is now experiencing a structural liquidity deficit.”

On Monday, February 28, the U.S. announced additional sanctions against Russia's central bank, targeting the National Wealth Fund of the Russian Federation and the Ministry of Finance of the Russian Federation. "“We wanted to put these actions in place before our markets open because what we learned over the course of the weekend from our allies and partners was the Russian Central Bank was attempting to move assets and there would be a great deal of asset flight starting on Monday morning from institutions around the world,” according to a Biden administration official.

The Russian stock exchange remained closed Monday. According to the Wall Street Journal, "The Bank of Russia took a raft of measures early Monday to protect Russia’s banking system. It raised benchmark rates to 20% from 9.5% in an attempt to attract savings into banks, the largest of which were targeted by Western sanctions and will be all but cut off from international markets."

Switzerland also announced the country would break its neutral status and join the Russian sanctions implemented by the EU.

Related sanctions news:

On Saturday, February 26, The U.S., European Union, Canada and U.K. announced a third round of prohibitive sanctions against Russia, including removing select Russian banks from the Swift financial network. "This will ensure that these banks are disconnected from the international financial system and harm their ability to operate globally," the U.S. said in a joint statement. The U.S. and E.U. also announced "Restrictive measures that will prevent the Russian Central Bank from deploying its international reserves in ways that undermine the impact of our sanctions."

According to the Wall Street Journal, "The moves announced also created a task force to go after the physical assets of sanctioned companies and Russian oligarchs—including their yachts, luxury cars and homes—as well as an effort to curb so-called golden passports that allow Russian elites to essentially buy citizenship in other countries."

On Friday, February 25, European Commission president Ursula von der Leyen previewed a new round of sanctions against Russia, including financial sanctions that target 70% of the Russian banking market. The sanctions also target energy, airline and technology sectors. And Australian Prime Minister Scott Morrison announced a fresh round of sanctions targeting "oligarchs whose economic weight is of strategic significance to Moscow" and members of the Russian parliament who voted to send Russian troops into Ukraine.

U.S. banks remain concerned about potential cyberattacks. According to the Wall Street Journal, "Biden administration officials have told banks they intend to share intelligence among multiple U.S. agencies in order to mount a quick response, but the officials haven’t spelled out what any response might be."

Also on Friday, Russia's central bank said customers of sanction-hit Russian banks, including VTB Group, Sovcombank, Novikombank, Promsvyazbank, and Otkritie, are unable to use Apple and Google Pay.
(Related WSJ news: U.S. Sanctions Against VTB and Sberbank Aim to Disrupt Russia’s Economy)

On Thursday, February 24, President Joe Biden announced a new and more severe round of sanctions against Russia. The U.S. Treasury Department has blacklisted Russia’s two largest banks, VTB and Sberbank. "With today’s actions, we have now sanctioned Russian banks that hold around $1 trillion in assets," said the President. The EU is also considering additional sanctions but as of now, Russia will not be removed from The Society for Worldwide Interbank Financial Telecommunication, or SWIFT. after several EU nations, including Italy and Germany, raised concerns. "It is always an option," Biden said at Thursday's White House briefing, "but right now it's not the position that the rest of Europe wishes to take."

Cyberattacks continue to be a concern. On Wednesday, February 23, Ukraine authorities announced distributed denial of service (DDOS) attacks had taken two unnamed banks offline, as well as numerous government agencies.

Here is a summary of other actions taken since the crisis began:

Actions taken by the U.S. government:

On Wednesday, February 23, President Biden announced that the U.S. would impose new sanctions on the Nord Stream 2 pipeline and its corporate officers.
On Tuesday, February 22, President Biden ordered heavy financial sanctions against Russian bank VEB and its military bank. American financial institutions will be prohibited from processing transactions for VEB.
The U.S. is no longer buying Russia’s sovereign debt. “That means we’ve cut off Russia’s government from Western financing,” President Biden said Tuesday, February 22. “It can no longer raise money from the West and cannot trade its new debt on our markets, or European markets either.”

Actions taken by the United Kingdom:

The U.K. will impose sanctions against five Russian banks - Rossiya bank, IS bank, General bank, Promsvyazbank and Black Sea bank.
The U.K. will impose travel bans and asset freezes on three wealthy Russian individuals: Gennady Timchenko, Boris Rotenberg, and Igor Rotenberg.

Actions from the European Union:

The EU is levying their own initial set of sanctions, targeting Russian officials over their actions in Ukraine.
Three banks that are financing Russian military and other operations are also being targeted with sanctions: VEB, Rossiya, and Promsvyazbank. Senior officials at the three banks are also being targeted with sanctions, including Igor Shuvalov, the head of VEB and a former first deputy prime minister of Russia.
On Wednesday, February 23, the EU announced additional sanctions against Russia’s Defense Minister Sergei Shoigu and Russia’s Internet Research Agency.
Germany also halted the process of certifying the Nord Stream 2 gas pipeline from Russia.

Additional actions:

On Wednesday, February 23, Japan and Australia announced sanctions in response to Russia's deployment of troops into Donetsk and Lugansk. Both countries imposed sanctions on Russia and individuals linked to eastern Ukraine. Japan also banned the issuing and trade of Russian government bonds in their country.

The Risk Management Association and Debevoise & Plimpton hosted a Risk Readiness webinar Feb 24, 2022 to review the latest sanctions that have been implemented and the compliance and risk management considerations for banks. If you would like to watch the session On-Demand, please click here to view the recording and download a copy of the slides here.