OFAC Russian War Sanctions
U.S. sanctions on designated banks and financial institutions affected about 80 percent of all banking assets in Russia and
U.S. persons/institutions which need to “exit” the existing relationships.
Activities Subject to Secondary Sanctions Risk. Non-U.S. persons may be exposed to secondary sanctions risk and could be designated for property-blocking sanctions for assisting, sponsoring, or providing financial, material, or technological support for, goods or services to or in support of persons blocked under the Executive Order (E.O.) 14024.
The OFAC sanctions barred access to the U.S. professional services that are used by wealthy Russians and state-owned or controlled enterprises to set up shell companies, move wealth and resources to alternate jurisdictions, and conceal assets from authorities around the world to evade U.S. sanctions and generate revenue for the Russian economy.
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OFAC-Prohibited Accounting, Trust and Corporate Formation, and Management Consulting Services:
The exportation, re-exportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of accounting, trust, and corporate formation, or management consulting services to any person located in the Russian Federation.
Prohibited Activities’ Exclusions:
(1) Any service to an entity located in the Russian Federation that is owned or controlled, directly or indirectly, by a United States person.
(2) Any service in connection with the wind-down or divestiture of an entity located in the Russian Federation that is not owned or controlled, directly or indirectly, by a Russian person.
“Accounting services” – includes services related to the measurement, processing, and evaluation of financial data about economic entities.
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“Trust and corporate formation services” – includes services related to assisting persons in forming or structuring legal persons, such as trusts and corporations; acting or arranging for other persons to act as directors, secretaries, administrative trustees, trust fiduciaries, registered agents, or nominee shareholders of legal persons; providing a registered office, business address, correspondence address, or administrative address for legal persons; and providing administrative services for trusts.  
“Management consulting services” – includes services related to strategic business advice; organizational and systems planning, evaluation, and selection; development or evaluation of marketing programs or implementation; mergers, acquisitions, and organizational structure; staff augmentation and human resources policies and practices; and brand management.
“Russian person” – an individual who is a citizen or national of the Russian Federation, or an entity organized under the laws of the Russian Federation.
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Prohibited Services’ Exceptions:
(1) any service to an entity located in the Russian Federation that is owned or controlled, directly or indirectly, by a U.S. person; and
(2) any service in connection with the wind-down or divestiture of an entity located in the Russian Federation that is not owned or controlled, directly or indirectly, by a Russian person.
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“Credit rating services” means services related to assessments of a borrower’s ability to meet financial commitments, including analysis of general creditworthiness or for a specific debt or financial obligation.
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“Auditing services” means the examination or inspection of business records by an auditor, including checking and verifying accounts, statements, or other representations of the financial position or regulatory compliance of the auditee.
SANCTIONS’ CONSEQUENCES: 
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All property and interests in the property of said designated persons that are in the U.S.A. or in the possession or control of U.S. persons are blocked and must be reported to OFAC.
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Entities that are owned, directly or indirectly, 50 percent or more by one or more blocked persons are also blocked.
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All transactions by U.S. persons or within (or transiting) the U.S.A. that involve any property or interests in property of designated or otherwise blocked persons are prohibited unless authorized by a general or specific OFAC license or otherwise exempt.
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These prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any blocked person and the receipt of any contribution or provision of funds, goods, or services from any such person.
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The exportation, re-exportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of accounting, trust and corporate formation, or management consulting services to any person located in the Russian Federation are prohibited starting from June 7, 2022. 
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Release of funds. To seek release of the funds blocked at a U.S. Financial Institution, a party to a funds transfer may:
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Apply’s documents related to the underlying transaction with OFAC with a copy of the original payment or transfer instructions
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Attach invoices, bills of lading, government-issued identification such as passport, temporary/permanent resident card, birth certificate, or other identifying documentation for both the remitter and the beneficiary. 
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All documents must be in English or include an English translation.
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A copy of the application and all related documentation must be retained by the applicant for at least five years after the date of the underlying transaction.
The European Commission and EU's similar cross-border/global sanction measures echo U.S. asset recovery and confiscation for EU crimes: terrorism, illicit arms/drug / human trafficking, sexual exploitation of women and children, money counterfeiting and laundering, corruption, and computer and organized crimes.
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REFERENCES
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E.O. 14024 Blocking Sanctions
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FAQ 1035
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“Prohibitions Related to Certain Accounting, Trust and Corporate Formation, and Management Consulting Services”, 5/8/22 Determination per E.O. 14071
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Determination of May 8, 2022, made pursuant to E.O. 14071