OFSI has published an update summarising the impact of the changes to the Russian sanctions regulations that took effect from 15 December 2023. The changes mean that a bank cannot process any payment that has previously been processed by a bank that is a Designated Person or which is intended for a bank that is designated. The change bans banks from processing any relevant transaction even if the account holders sending and receiving the funds are not in any way designated or sanctioned. OFSI thinks most of the transactions that will be affected by the chains will be those that have used correspondent banking at some point and the correspondent bank is a Designated Person.
