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	Comments on: Case of the Day: VTB Bank v. Mavlyanov	</title>
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	<link>https://lettersblogatory.com/2018/02/05/case-of-the-day-vtb-bank-v-mavlyanov/</link>
	<description>The Blog of International Judicial Assistance</description>
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		<title>
		By: Ted Folkman		</title>
		<link>https://lettersblogatory.com/2018/02/05/case-of-the-day-vtb-bank-v-mavlyanov/#comment-3026</link>

		<dc:creator><![CDATA[Ted Folkman]]></dc:creator>
		<pubDate>Tue, 06 Feb 2018 16:04:56 +0000</pubDate>
		<guid isPermaLink="false">https://lettersblogatory.com/?p=25990#comment-3026</guid>

					<description><![CDATA[In reply to &lt;a href=&quot;https://lettersblogatory.com/2018/02/05/case-of-the-day-vtb-bank-v-mavlyanov/#comment-3025&quot;&gt;Marian Dent&lt;/a&gt;.

That is very helpful, Marian! I knew someone would know the answer to this question. I think the question of chutzpah remains, but you&#039;ve sorted out the legal question very clearly.]]></description>
			<content:encoded><![CDATA[<p>In reply to <a href="https://lettersblogatory.com/2018/02/05/case-of-the-day-vtb-bank-v-mavlyanov/#comment-3025">Marian Dent</a>.</p>
<p>That is very helpful, Marian! I knew someone would know the answer to this question. I think the question of chutzpah remains, but you&#8217;ve sorted out the legal question very clearly.</p>
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		<title>
		By: Marian Dent		</title>
		<link>https://lettersblogatory.com/2018/02/05/case-of-the-day-vtb-bank-v-mavlyanov/#comment-3025</link>

		<dc:creator><![CDATA[Marian Dent]]></dc:creator>
		<pubDate>Tue, 06 Feb 2018 15:22:12 +0000</pubDate>
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					<description><![CDATA[Dear Ted, Your confusion is because you are mistaken about the type of sanctions imposed against VTB.  VTB is on the Sectoral Sanctions (SSI) list.  Sectoral Sanctions are a new type of sanction started especially for the Ukraine related sanctions against Russia.  Sectoral Sanctions are mainly against the banking sector, and prevent US companies and individuals from extending credit to the VTB longer than what is now about 14 days (but until recently was longer).  However, the SSI list, unlike the Specially Designated Nationals (SDN) list, does not require US parties to seize assets and does not otherwise prevent US parties from dealing with the listed entities altogether.  I believe that VTB still regularly trades in dollars and, although I think it closed its New York office, still has many dealings in the US.  Best Regards, Marian]]></description>
			<content:encoded><![CDATA[<p>Dear Ted, Your confusion is because you are mistaken about the type of sanctions imposed against VTB.  VTB is on the Sectoral Sanctions (SSI) list.  Sectoral Sanctions are a new type of sanction started especially for the Ukraine related sanctions against Russia.  Sectoral Sanctions are mainly against the banking sector, and prevent US companies and individuals from extending credit to the VTB longer than what is now about 14 days (but until recently was longer).  However, the SSI list, unlike the Specially Designated Nationals (SDN) list, does not require US parties to seize assets and does not otherwise prevent US parties from dealing with the listed entities altogether.  I believe that VTB still regularly trades in dollars and, although I think it closed its New York office, still has many dealings in the US.  Best Regards, Marian</p>
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