Making Sense of Sanctions Versus SWIFT Delisting
On February 27, 2022, the U.S., UK and EU announced their agreement that certain Russian banks would be delisted from the Belgian-based Society for Worldwide Interbank Financial Telecommunication (SWIFT). The EU, which has jurisdiction over SWIFT, implemented sanctions measures that will ban the organization, effective March 12, 2022, from providing financial messaging support anywhere in the world for the following Russian financial institutions and their Russian subsidiaries:
- Bank Otkritie;
- Promsvyazbank (PSB);
- Bank Rossiya;
- Vnesheconombank (VEB); and
- VTB Bank
The SWIFT announcement has raised questions about how this action relates to existing sanctions and general licenses for Russian banks. We explore the differences below.