Agent makes cross-border payment touching Russia

Situation: An agent initiates a B2B payment from the US to a European company. The payment is in USD and routes through a correspondent bank that processes part of the transaction through a subsidiary in Russia's financial sector — subject to sectoral sanctions under Directive 1.

Risk: The US originator may have facilitated a transaction with a sanctioned sector. Even if the ultimate beneficiary is clean, the intermediary path matters.