OFAC GL for Subways & ATMs in Hong Kong

Chinese Armored Car Service VPower Finance Security (Hong Kong) can continue to service automated teller machines and subway farecard vending in the former Crown Colony according to General License 102 of the Russian Harmful Foreign Activities Sanctions Regulations.

The security firm had been included on the list of Specially Designated Nationals and Blocked Persons list ("SDN List") released June 12, 2024 by the Treasury.

On December 22, 2023, President Biden issued E.O. 14114 “Taking Additional Steps With Respect to the Russian Federation’s Harmful Activities.” which amends E.O. 14024 and E.O. 14068, providing OFAC with the authority to impose certain secondary sanctions on foreign financial institutions determined,

• knowingly or unknowingly, to have engaged in any significant transaction for or on behalf of certain entities designated under E.O. 14024, or
• to have engaged in any significant transaction or provided any service involving the broadly-defined Russian military-industrial base."

As part of the measures issued by Treasury on June 12, 2024, OFAC issued FAQ 1181, which expands the scope of what OFAC considers to be “Russia’s military-industrial base” to include all persons subject to blocking sanctions under EO 14024. 

This means that FFIs risk being sanctioned for conducting or facilitating significant transactions, or providing any service, involving any person blocked under EO 14024, including several large Russian banks not previously covered by the definition of “Russia’s military-industrial base.”

OFAC also published an updated Compliance Advisory to Foreign Banks on Russia Sanctions Risks in order to provide additional guidance for Foreign Financial Institutions.