The US Treasury’s Office of Foreign Assets Control (OFAC) designated VTB, Russia’s second-largest bank, on the Specially Designated Nationals (SDN) List on September 9 for facilitating Iranian sanctions evasion under Executive Order 13902. This designation, layered on top of existing penalties related to Crimea (2014) and the Ukraine invasion (2022), freezes all US-jurisdiction assets and prohibits any transactions by Americans with the bank, with no general licenses or exceptions. The action is part of « Operation Economic Outcast, » a sweeping campaign targeting financial networks enabling Iran to circumvent international sanctions. For third-country banks, any institution still facilitating transactions with VTB faces potential devastating secondary sanctions. VTB is now sanctioned under at least three distinct legal authorities, making it one of the most restricted financial institutions on the planet.
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