Treasury implements REPO for Ukranians Act

The Treasury Department yesterday announced that, as part of implementing the historic Rebuilding Economic Prosperity and Opportunity for Ukrainians Act (the “REPO for Ukrainians Act”), OFAC has issued a new reporting requirement for financial institutions holding Russian sovereign assets. Under section 104(a) of the Act, all financial institutions at which Russian sovereign assets are located, and that know or should know of such assets, must provide notice of such assets to OFAC no later than August 2, 2024 or within 10 days of the detection of such assets, and can do so via OFAC’s new form, which can be found on OFAC's Reporting System webpage.