On November 21, 2024, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated dozens of Russian banks, including Gazprombank and other Russian banks, securities registrars, and finance officials, to the List of Specially Designated Nationals and Blocked Persons (“SDN List”). The full SDN designation of Gazprombank, the largest remaining Russian bank, is particularly notable given its role in supporting gas flows between Russia and remaining European and other customers. On the…