payable-through account in the United States for a foreign
financial institution in a manner that is inconsistent with any strict condition imposed and in effect
pursuant to this section.
(b) Sanctionable activity by foreign financial institutions involving certain activity for persons
with respect to which sanctions are imposed pursuant to section 4 of the Ukraine Freedom
Support Act of 2014, as amended (22 U.S.C. 8921-8930) (UFSA).
[…]
(c) Sanctionable activity by foreign financial institutions on behalf of Russian persons included
on the SDN List.