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OFAC Issues Guidance on Credit Cards Issues by Russian Banks

The Office of Foreign Assets Control on April 20 issued guidance for holders of credit cards issued by sanctioned Russian financial institutions. The agency said U.S. operators of credit card systems are blocked from processing transactions involving certain sanctioned foreign financial institutions unless exempt by OFAC. Foreign operators of credit card systems whose payment cards are issued by sanctioned banks also risk violating U.S. sanctions if they allow those cards to be used in the U.S., OFAC said.

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OFAC said companies can take several due diligence steps to comply with the sanctions, including requesting the Bank Identification Numbers of sanctioned banks, disabling those BINs from operation in the U.S., and requesting that non-U.S. operators "prevent the use of payment cards issued by sanctioned foreign financial institutions in the United States at the network level."