Debate persists on when an independent undertaking is issued: upon leaving the issuer’s control or only when advised to the beneficiary. Various rules clarify issuance timing.
On 20 April 2022, U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated Russian bank, Transkapitalbank (TSB), and a global network of more than 40 individuals and entities as being involved in attempts to evade sanctions. According to a US Treasury press release, the network was led by Russian oligarch Konstantin Malofeyev. The release also identified TSB as “at the heart of sanctions evasion” and responsible for suggesting options to evade international sanctions.
According to US Treasury:
“For example, to avoid detection and sanctions-derived restrictions, TKB has offered its clients the ability to conduct transactions via its proprietary Internet-based banking system, known as TKB Business, an alternative communication channel to the Society for Worldwide Interbank Financial Telecommunication (SWIFT) network, including for the purpose of processing U.S. dollar payments for sanctioned clients. TKB has also sought to create a settlement hub in Asia without involving U.S. or European banks in the clearing process.”
All entities owned 50 percent or more, directly or indirectly by TKB, are subject to blocking under Executive Order 14024 even if not identified by OFAC.
Debate persists on when an independent undertaking is issued: upon leaving the issuer’s control or only when advised to the beneficiary. Various rules clarify issuance timing.
On 15 Feb 2023, DCSA members pledged to issue 50% of bills of lading (B/Ls) electronically by 2028 and 100% by 2030, aiming to cut costs and boost global trade.
