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Sberbank and the "50 Percent Rule" risk - Feb 2022


Russia's largest financial institution, Sberbank and 25 of its subsidiaries were hit with punitive restrictions as part of a larger effort to undermine the Russian financial sector.

However, Sberbank has hundreds of subsidiaries located across dozens of jurisdictions subject to those same restrictions and OFAC's "50 Percent Rule" that don't appear on any government list.

Food for thought:-