On September 14, 2026, VTB Bank Public Joint Stock Company, a major bank of the Russian Federation, became one of the world’s most extensively sanctioned financial institutions. OFAC, which had already designated VTB in 2022 under Executive Order 14024 to cut off its support to Russia following that country’s invasion of Ukraine, imposed a new designation under Operation Economic Outcast to further prevent VTB’s efforts to facilitate Russia’s support of Iran and evade sanctions laws. The U.S. also substantially expanded the sanction risks for entities that continue to do business with Iran (see EO 13902).
VTB has made concerted efforts over the past few years to establish correspondent banking relationships with banks, including those subject to Iranian sanctions regulations. This has encompassed establishing settlement capabilities for transactions involving Iranian rials and Russian rubles which has allowed VTB to move billions in Iranian assets frozen under U.S. and other international sanctions regimes.
As a result of the designations, banks including non-U.S. financial institutions that deal with VTB should immediately terminate those relationships or face even greater sanctions risk under both primary and secondary sanctions regulations.
As this recent designation makes clear, the U.S. will aggressively target U.S. and non-U.S. entities that engage in funding Iran and other sanctioned countries’ illegal revenues or evade sanctions regulations.