The OverRuled: Sanctions Module has been updated with the following actions:
- 26 Jul 2024 - State Street Bank and Trust Company - USD $7,452,501
Between 2016 and 2020, Charles River Systems, Inc., a subsidiary of State Street Bank and Trust Company, redacted or reissued invoices for certain customers who were subject to Directive 1 of Executive Order 13662, as well as accepting certain payments from these customers outside of the applicable debt tenor.
The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 24 Jul 2024 (EU):
The European Commission (the “Commission”) updated its Russia sanctions FAQs in respect of Central Securities Depositories ("CSD"). The updated FAQs provide further clarification on the following: (i) whether Depositary Receipts ("DRs") of Russian issuers can be converted into the underlying shares; (ii) whether the conversion of DRs is permitted by Article 6(b)5aa of Council Regulation (EU) No. 269/2014; (iii) whether 'free-of-payment' transfers between sub-accounts within the same EU financial institution or CSD are permitted for Russian shares not targeted by EU sanctions; (iv) whether EU persons and entities may transfer or sell DRs with Russian underlying securities on the secondary market without conversion; and (v) whether EU persons and entities can participate in 'asset swap' schemes implemented by Russian Presidential decree 844.
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