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The Office of Foreign Assets Control designated twelve mid-sized Russian state-owned and majority-owned lenders on the Specially Designated Nationals list, closing a correspondent-banking loophole flagged in the December 2025 OFAC advisory on payment-chain layering. The action extends secondary-sanctions exposure to any non-U.S. financial institution facilitating transactions with the listed entities, reinforcing the tier-1 program established in 2024. Coordinated announcements from the UK OFSI and the EU Council followed the same day, though U.S. designations are broader in scope and cover entities previously shielded by nested correspondent arrangements.
Treasury cited accelerating evasion through mid-sized lenders acting as nested correspondents for tier-1 designated banks. The January action closes a loophole flagged in OFAC's December 2025 advisory on payment-chain layering.
Secondary-sanctions exposure shifts enforcement cost onto non-U.S. financial institutions, which face a binary choice: exit Russia-linked relationships entirely or risk losing U.S. dollar clearing. EU regulators have signaled informal alignment but no reciprocal designations.
Coordinated with UK OFSI and EU 18th sanctions package, though the U.S. designations are broader. Russia's central bank preemptively announced contingency liquidity lines for the listed entities.