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TCH Comments on Possible OFAC Sanctions on Russia

Responding to reports that the Administration is considering broad sanctions on whole segments of the Russian economy in response to the crisis in Ukraine, TCH sent an unsolicited letter to the Office of Foreign Assets Control pointing out some of the adverse effects that these sanctions could have on U.S. financial institutions. The letter suggests ways that these adverse effects could be mitigated and provides statistics on Russian payments through CHIPS to provide OFAC with information on the approximate size of Russian payment flows in U.S. dollars.