2022 Trust Forum Presentations

INTERNAL FR/OFFICIAL USE // SECURE EXTERNAL

• Determination pursuant to EO 14071 • Prohibits exportation, reexportation, sale, or supply, directly or indirectly to any person located in the Russian Federation of: o accounting services o trust and corporate formation services o management consulting services • FAQ 1034 defines the services • FAQ 1058 defines person located in the Russian Federation • Applies to both new and existing trusts and companies • Adequacy of a bank’s due diligence for trust customers (including authority and control) is key to successful compliance Trust Services Ban

11/3/2022

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INTERNAL FR/OFFICIAL USE // SECURE EXTERNAL

• Essentially forces non-U.S. individuals and entities to “pick a side” • Risk OFAC imposing blocking sanctions on them if they assist, support, or sponsor attempts by Russia and SDNs to evade sanctions o FAQ 1082 National Payment Card System Joint Stock Company (NSPK) and the Russian MIR National Payment System it operates ƒ NSPK is not a blocked entity, but they process transactions for designated Russian banks and could be used to process transactions for SDNs or other sanctioned activities ƒ If a non-U.S. financial institution enters into new or expanded agreements with NSPK, they risk supporting Russia’s efforts to evade sanctions ƒ Various foreign banks have since dropped services for the MIR card, including banks in Turkey, Armenia, Kazakhstan, Uzbekistan, and Vietnam o FAQ 1092 Provision of ammunition or other military goods or supporting Russia’s military-industrial complex Secondary Sanctions

11/3/2022

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