Talk:VTB Bank

Quick review of edits

I was asked to review edits made to this article in 2016. I looked through most of the edits, and I feel although many are without edit comments (editors: please summarise what you are changing each time) and some lost supporting citations, they're probably Ok in terms of the article balance. Please note I am quite unfamiliar with VTB history outside of its acquisition of Bank of Moscow. One of the wikilinks was wrong and certainly needed delinking, there were a lot of redlinks (which I'm Ok with but many others find them annoying) and the management structure has been updated. I personally would have respected the HTML comment request to keep the corporate history from 2009 to 2012, but some of it would need sourcing to archived pages from VTB to restore in accordance with WP:V. I'll leave that to editor consensus. I may restore a couple of citations that were lost that would support the claim of the list of banks acquired from 2011 to 2016, but I have little time and even less ability to handle Cyrillic sources to do much more. -84user (talk) 18:11, 6 August 2016 (UTC)

EDIT to add I recommend the lede be edited to better reflect the size and importance of VTB, and the fact that it is state controlled, at least according to my quick look at German and UK sources (subscriber walled [1]) it has the second largest Tier 1 capital (18 billion USD, world rank 76) in Russia after Sberbank (30 billion USD, world rank 51). For perspective the Chinese bank sector has over ten times the tier 1 capital (ICBC alone has 274 billion). -84user (talk) 19:03, 6 August 2016 (UTC)

External links modified

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False claims regarding sanctions

There are at least two false claims in edits made by 67.53.214.86 (talk). I have previously removed said claims but the user have undid my changes as "Vandalism". I will make the case here for why they are false and remove the entries again afterwards.

False Claim: VTB was on the OFAC SDN list

Original claim:

29 July 2014: the Office of Foreign Assets Control (OFAC) published that VTB Bank OAO, which is the second largest bank in Russia, together with its subsidiaries (“the VTB Group”) and the Bank of Moscow through its parent bank, VTB Bank OAO, and other entities have been added to the Specially Designated Nationals List (SDN). This freezes the assets in the United States of VTB, VTB Global, Bank of Moscow, and other entities; and blocks any United States citizen or entities from conducting business with VTB, VTB Global, Bank of Moscow, and other entities.

For this claim there is a whole gish gallop of citations. But to establish the truth here is fairly simple:

1. VTB is not on the current SDN List
2. VTB is not in Archive of Specially Designated Nationals (SDN) List Changes from 1994 to Present. To confirm this without opening each manually you can use this on linux with bash:

   curl --silent 'https://www.treasury.gov/resource-center/sanctions/SDN-List/Pages/archive.aspx' \
   | xmllint --html --xpath '//*[text()="Archive of Specially Designated Nationals (SDN) List Changes from 1994 to Present (in .txt format)"]/..//a/@href' - 2>/dev/null \
   | sed -n 's| href="\([^"]\+\)"|https://www.treasury.gov\1\n|gp' \
   | xargs -n1 -t curl --silent | grep -i vtb
   

3. VTB is not in historical OFAC SDN lists from the internet archive. To confirm this without opening each manually you can use this on linux with bash:

   curl --silent http://web.archive.org/web/timemap/link/https://www.treasury.gov/ofac/downloads/sdnlist.txt \
   | tr -d '\r' | gawk -F';' '(match($0,"<(http://web.archive.org/web/([0-9]*)/(.*/([^/]+)))>",groups)){ print groups[1] }' \
   | xargs -I{} -t curl --silent {} | grep -i vtb
   

Dealing specifically with each of the citations used to show none of them support the claim:

1. "Announcement of Additional Treasury Sanctions on Russian Financial Institutions and on a Defense Technology Entity"
   1. This does not mention OFAC SDN List at all
   2. This specifically says

      We have not blocked the property or interests in property of these banks, nor prohibited transactions with them beyond these specific restrictions.

      This language is quite measured. SDN individuals are referred to as blocked. SSI individuals are not blocked but only have prohibitions for specific types of transactions (more on this later).
2. "Sectoral Sanctions Identifications; Kingpin Act Designations; Iran Designations Update; Ukraine-related Designation"
   1. This is broken up into 4 sections
      1. "The following individuals have been added to OFAC's SDN List:"
      2. "The following entities have been added to OFAC's SDN List:"
      3. "The following changes have been made to OFAC's SDN List:"
      4. "The following entities have been added to OFAC's Sectoral Sanctions Identifications List:"
   2. VTB is only listed under "The following entities have been added to OFAC's Sectoral Sanctions Identifications List:" and not under anything relating to OFAC's SDN List.
3. "Executive Order - Blocking Property of Additional Persons Contributing to the Situation in Ukraine"
   1. This is actually a duplicate of
   2. This does not mention VTB or SDN list.
4. "Ukraine-related Designations ~ Specially Designated Nationals List Update ~ 3/20/2014 ~ OFFICE OF FOREIGN ASSETS CONTROL"
   1. This does not mention VTB.
5. "Specially Designated Nationals And Blocked Persons List (SDN) Human Readable Lists"
   1. The list does not mention VTB
6. "Ukraine conflict: US and EU widen sanctions on Russia"
   1. Does not mention SDN
7. "Ukraine EO13660"
   1. Does not mention SDN or VTB
8. "Ukraine EO13661"
   1. Does not mention SDN or VTB
9. "Ukraine EO13662"
   1. Does not mention SDN or VTB
10. "Time for Trump to remove US sanctions against Russian banks – VTB head"
    1. Does not mention SDN

So to sum up:

1. Not one of the citations suggests the claim is true
2. Some of the citations refutes the claim
3. VTB was added to SSI list in 2014 under directive 1 pursuant to EO, it was never on SDN list - these lists are not even slightly similar in nature. Being listed on SSI list does not freeze your assets nor does it blocks any United States citizen or entities from conducting business with VTB. It restricts only specific types of business which involves buying equity issued by VTB or lending money to VTB (i.e. buying debt issued by VTB). It is perfectly legal to for example sell equity to VTB or get a loan from VTB.

False Claim: New sanctions were placed on VTB in 2015

Original claim:

22 December 2015: United States imposed additional sanctions on VTB Bank and its subsidiaries.

Again a bunch of wrong citations, not quite as many though. But direct refutation is still easiest here. Looking at changes made to SSI list there is the following relating to VTB:

1. 07/29/14: VTB BANK OAO appears for first time. There 11 entries containing VTB under the heading "The following [UKRAINE-EO13662] entries have been added to OFAC's Sectoral Sanctions Identifications List:". All of the entries have the same registration ID 1027739609391 and is either "VTB BANK OAO" or "a.k.a. VTB BANK OAO". The text for all of these are

   {VTB BANK DETAILS} 29, Bolshaya Morskaya str., St. Petersburg 190000, Russia; 37 Plyushchikha ul., Moscow 119121, Russia; 43, Vorontsovskaya str., Moscow 109044, Russia; SWIFT/BIC VTBRRUMM; Website www.vtb.com; Registration ID 1027739609391 (Russia); Tax ID No. 7702070139 (Russia); Government Gazette Number 00032520 (Russia); License 1000 (Russia); The following transactions by U.S. persons or within the United States are hereby prohibited: transacting in, providing financing for, or otherwise dealing in new debt of longer than 90 days maturity or new equity for these persons (listed here), their property, or their interests in property. All other transactions with these persons or involving any property in which one or more of these persons has an interest are permitted, provided such transactions do not otherwise involve property or interests in property of a person blocked pursuant to Executive Orders 13660, 13661, or 13662, or any other sanctions programs implemented by the Office of Foreign Assets Control. [UKRAINE-EO13662].

   . The emphasized part is the same as "Directives 1 Pursuant to EO 13662 (Issued July 16, 2014)" except for the (listed here) part.

   The following transactions by U.S. persons or within the United States are hereby prohibited: transacting in, providing financing for, or otherwise dealing in new debt of longer than 90 days maturity or new equity for these persons, their property, or their interests in property. All other transactions with these persons or involving any property in which one or more of these persons has an interest are permitted, provided such transactions do not otherwise involve property or interests in property of a person blocked pursuant to Executive Orders 13660, 13661, or 13662, or any other sanctions programs implemented by the Office of Foreign Assets Control.

2. 09/12/14: Again 11 entries, this time under heading "The following [UKRAINE-EO13662] entries have been changed:". All of the entries have the same registration ID 1027739609391 and is either "VTB BANK OAO" or "a.k.a. VTB BANK OAO". The text for all of these are

   {VTB BANK DETAILS} 29, Bolshaya Morskaya str., St. Petersburg 190000, Russia; 37 Plyushchikha ul., Moscow 119121, Russia; 43, Vorontsovskaya str., Moscow 109044, Russia; SWIFT/BIC VTBRRUMM; Website www.vtb.com; Registration ID 1027739609391 (Russia); Tax ID No. 7702070139 (Russia); Government Gazette Number 00032520 (Russia); License 1000 (Russia); The following transactions by U.S. persons or within the United States are hereby prohibited: transacting in, providing financing for, or otherwise dealing in new debt of longer than 90 days maturity or new equity for these persons (listed here), their property, or their interests in property. All other transactions with these persons or involving any property in which one or more of these persons has an interest are permitted, provided such transactions do not otherwise involve property or interests in property of a person blocked pursuant to Executive Orders 13660, 13661, or 13662, or any other sanctions programs implemented by the Office of Foreign Assets Control. [UKRAINE-EO13662]. -to- {VTB BANK DETAILS} 29, Bolshaya Morskaya str., St. Petersburg 190000, Russia; 37 Plyushchikha ul., Moscow 119121, Russia; 43, Vorontsovskaya str., Moscow 109044, Russia; SWIFT/BIC VTBRRUMM; Website www.vtb.com; Executive Order 13662 Directive Determination - Subject to Directive 1; Registration ID 1027739609391 (Russia); Tax ID No. 7702070139 (Russia); Government Gazette Number 00032520 (Russia); License 1000 (Russia); For more information on directives, please visit the following link: http://www.treasury.gov/resource- center/sanctions/Programs/Pages/ukraine.aspx#directives. [UKRAINE- EO13662].

   So instead of using the text of "Directives 1 Pursuant to EO 13662 (Issued July 16, 2014)" they now just reference it. Looking at the publication for this action this change is explained

   Please note: in order to preserve space in the SSI list's remarks field, OFAC is no longer publishing the full text of the directives associated with each SSI record. Instead, OFAC has created a parsable feature that indicates what directive number or numbers apply to the SSI record. Users of the SSI list can find the full text of each applicable directive by visiting the link that now appears in the remarks field of each SSI record.

   However there is also something else that happened on this date which is explained in the related announcement.

   Treasury has added Russia’s largest bank, Sberbank of Russia, to the existing prohibitions on U.S. persons providing equity or certain long-term debt financing. In addition, we have tightened the debt financing restrictions by reducing from 90 days to 30 days the maturity period for new debt issued by the six Russian banks subject to this restriction. These banks are Bank of Moscow, Gazprombank OAO, Russian Agricultural Bank, Sberbank, VEB, and VTB Bank.

   Directive 1 was also amended and published as "Directive 1 as Amended Under Executive Order 13662 (Issued September 12, 2014)" . The new text here is

   the following activities by a U.S. person or within the United States are prohibited, except to the extent provided by law or unless licensed or otherwise authorized by the Office of Foreign Assets Control: (1) all transactions in, provision of financing for, and other dealings in new debt of longer than 30 days maturity or new equity of persons determined to be subject to this Directive, their property, or their interests in property; and (2) all activities related to debt or equity issued before the date of this Directive 1 (as amended) that would have been prohibited by the prior version of this Directive 1. All other activities with these persons or involving their property or interests in property are permitted, provided such activities are not otherwise prohibited pursuant to Executive Orders 13660, 13661, or 13662 or any other sanctions program implemented by the Office of Foreign Assets Control.

3. 12/22/15: Here is 86 entries all with text

   {VTB BANK LINKED ENTITY DETAILS} Executive Order 13662 Directive Determination - Subject to Directive 1; {OPTIONAL VTB BANK LINKED ENTITY ID} For more information on directives, please visit the following link: http://www.treasury.gov/resource- center/sanctions/Programs/Pages/ukraine.aspx#directives [UKRAINE- EO13662] (Linked To: VTB BANK OAO).

   . What is happening here is explained in this action's announcement.

   Today, OFAC also identified a number of subsidiaries of VTB Bank, Sberbank, and Rostec as being owned 50 percent or more by their respective parent entities. The two banks and one defense company were previously sanctioned pursuant to E.O. 13662 in September 2014. The subsidiaries identified today were already subject to the same financing restrictions as their respective parent entities per OFAC’s Revised Guidance on Entities Owned by Persons Whose Property and Interests in Property Are Blocked (“50 percent rule guidance”), which can be found here. These identifications will help the public more effectively comply with the sanctions on VTB Bank, Sberbank, and Rostec.

   So these are not new sanctions or restrictions, these are explicit identification of entities already restricted due to their relation to VTB Bank which has been in place since the "50 percent rule guidance" was published on 2014-08-14.

All of this can be easily verified using the following command on linux with bash

curl --silent 'https://www.treasury.gov/resource-center/sanctions/SDN-List/Pages/archive.aspx' \
    | xmllint --html --xpath '//*[text()="Changes to the Sectoral Sanctions Identifications (SSI) List"]/..//a/@href' - 2>/dev/null \
    | sed -n 's| href="\([^"]\+\)"|https://www.treasury.gov\1\n|gp' | grep '.txt$' | tac \
    | xargs -n1 -t curl --silent | tr -d '\r' | echo $( sed -E -e 's/^(|.*(\)|\])[.])$/\1STARTPARA/g' ) | sed 's/STARTPARA/\n\n/g' \
    | sed 's/STARTPARA/\n\n/g' | sed -E -e 's/^\s+//g' -e 's/.*(Executive Order.*\(Linked To: VTB BANK OAO\)[.])/{LINKED ENTITY DETAILS} \1/g' -e 's/(^| -to- )([^)\]+ \([^)]*a.k.a. VTB BANK OAO[^)]*\)|VTB BANK OAO \(f.k.a. [^)]*\)),/\1{VTB BANK DETAILS}/g' \
    | sed -E -e 's/((Registration ID|Government Gazette Number) [^;]+; |)(For more.*\(Linked To: VTB BANK OAO\).)/{OPTIONAL VTB BANK LINKED ENTITY ID} \3/g' \
    | egrep -i -e 'VTB' -e '^[0-9]{2}/[0-9]{2}/[0-9]{2}:' -e '^The following' | uniq -c | sed -E 's/^\s+1\s+//'

Dealing specifically with each of the citations used to show none of them support the claim:

1. "Treasury Sanctions Individuals and Entities for Sanctions Evasion and Other Activities Related to Russia and Ukraine - 12/22/2015"
   1. this explicitly refutes the claim by saying

      The subsidiaries identified today were already subject to the same financing restrictions as their respective parent entities

2. "Ukraine-related Designations - 12/22/2015"
   1. All entries mentioning VTB is listed as "Linked To: VTB BANK OAO"
3. "Executive Order - Blocking Property of Additional Persons Contributing to the Situation in Ukraine"
   1. Does not mention VTB or SDN - document is from March 20, 2014 so it cannot support claim for 2015
4. "Ukraine-related Designations 3/20/2014"
   1. Dated 2014 so cannot support claim for 2015 - but additionally it does not mention VTB once.
5. "Ukraine-related Designations 3/20/2014"
   1. Dated 2014 so cannot support claim for 2015 - but additionally it does not mention VTB once.
6. "Ukraine EO13662"
   1. Does not mention VTB or SDN - document is from March 20, 2014 so it cannot support claim for 2015

So to sum up:

1. Sanctions were imposed on 07/29/14
2. A guideline was published on 08/13/14 that indicated that sanctions extend to all entities in which listed entities have 50% or greater interest (i.e. linked entities).
3. Sanctions were tightened on 09/12/14
4. VTB linked entities sanctioned since 08/13/14 by the "50 percent rule guidance" were explicitly listed on 12/22/15.

Soh.Miero (talk) 00:07, 23 March 2018 (UTC)

Discussion

Hi, it is a reliable source from the United States government.67.53.214.86 (talk) 01:46, 23 March 2018 (UTC)

• I have updated references for 29 July 2014 and 22 December 2015 by removing three references for lack of support. The other references fully support the statements.
• The writeup for the Swiss entry has been clarified. I fully agree adding a reference that has a list of the specific banks sanctioned by Switzerland. On several different days, I have searched the Swiss law for the list, but have not found the correct list. However, for now, these are the best references that I have found. Of course, I could add RT articles, but the RT articles are not specific about which companies are sanctioned.
• I corrected the url for the EU sanctions on 31 July 2014. This reference clearly states VTB Bank.
  • Thank you for your discussion.67.53.214.86 (talk) 03:44, 23 March 2018 (UTC)

Other wikipedias have separate articles for VTB Group. The English wikipedia has redirects for VTB Group and VTB to this page. The references that list subsidiaries of VTB are appropriate for this article.67.53.214.86 (talk) 03:50, 23 March 2018 (UTC)

I improved writeup from Specially Designated Nationals List to Sectoral Sanctions Identifications List.67.53.214.86 (talk) 04:10, 23 March 2018 (UTC)

I improved the writeup about the United States sanctions to address the four points in your summation. Also, I removed three more references for lack of support. Thank you! I greatly appreciate your discussion to improve this article.67.53.214.86 (talk) 05:17, 23 March 2018 (UTC)

Any references to the United States CAATSA has not been added to this article. Of course, they will be added to this article.67.53.214.86 (talk) 05:34, 23 March 2018 (UTC)

I improved the writeup to be more specific for sanctions by United States under Executive Order 13662, its Directive 1, and amendments to the Directive 1.67.53.214.86 (talk) 23:49, 24 March 2018 (UTC)

• Once again, thank you for your extremely useful discussion!67.53.214.86 (talk) 23:53, 24 March 2018 (UTC)

@67.53.214.86: Last I checked your references are still inaccurate even though your claims are now more accurate. I was trying to fix the references when I got blocked from wikipedia and I still have only been partially unblocked after spending hours to correct it and really have just run down my energy to work on this. It would be good to fix the references but I'm no longer going to work on this. --Soh.Miero (talk) 17:55, 20 April 2018 (UTC)