UK Adds 3 Sanctions FAQs Following Mergers Involving Rosbank, Bank Otkritie
The U.K. Office of Financial Sanctions Implementation on April 23 added three FAQs to address issues surrounding the use of sanctions licenses that mention Rosbank PJSC and Bank Otkritie.
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Question 146 concerns the continued mention of Rosbank on sanctions licenses, given that the bank merged with TBank on Jan. 1. OFSI said mentions of Rosbank on licenses have been changed to reflect that. Holders of licenses mentioning Rosbank who wish to continue relying on them "should immediately request an amendment to your licence from OFSI," since the agency would consider it a sanctions breach should an incorrect license be used.
Question 148 says OFSI amended the live general licenses that mention Rosbank to reflect its merger with TBank. The agency "will not proactively identify specific licences referring to these entities."
Question 147 deals with a similar issue, since Bank Otkritie merged with BM-Bank on Jan. 1. OFSI said the bank is still sanctioned, since it's still controlled by the sanctioned entity VTB Bank. Holders of licenses mentioning Bank Otkritie who wish to continue using them also should immediately request an amendment.