Russian Sovereign Asset Reporting Requirements for Financial Institutions

ASSOCIATED BANC-CORP

Associated Banc-Corp operates as a financial institution providing lending, deposit solutions, and specialized financial services, directly falling under the rule's jurisdiction for financial institutions holding Russian sovereign assets or maintaining correspondent accounts. The company's corporate and commercial specialty segment serving financial institutions and its overall banking operations align with the reporting requirements for identifying and disclosing such assets. The rule specifically targets financial institutions holding Russian sovereign assets or maintaining correspondent accounts for foreign financial institutions, which does not align with the company's disclosed risk factors focused on capital ratios, credit losses, and economic sensitivity. The company's single regulatory compliance risk is generic capital requirements, not asset-specific reporting obligations like those mandated by this rule.

Axos Financial, Inc.

Axos Financial operates as a diversified financial institution with banking and securities segments, including correspondent banking channels and custody services that would likely hold or process Russian sovereign assets. The company's banking business specifically mentions correspondent channels, directly aligning with the rule's requirements for financial institutions maintaining correspondent accounts to exercise due diligence and report Russian sovereign assets. The rule focuses on mandatory reporting of Russian sovereign assets by financial institutions, which does not align with any of the company's disclosed risk factors. The company's risks center on credit losses, fair value estimation, economic uncertainty, goodwill impairment, and non-GAAP measures - none of which relate to foreign asset reporting or OFAC compliance requirements.

AMERICAN EXPRESS CO

American Express operates as a financial institution through its AENB depository institution subsidiary and maintains correspondent banking relationships internationally, directly falling under the rule's requirements to report Russian sovereign assets and exercise due diligence on correspondent accounts. The rule specifically targets financial institutions holding Russian sovereign assets or maintaining correspondent accounts for foreign financial institutions, which does not align with the company's disclosed risk factors focused on economic downturns, competition, digital payment disruption, and general risk management. While the company has regulatory compliance risks identified, none specifically mention foreign asset reporting, sovereign assets, or OFAC requirements related to Russian assets.

BankUnited, Inc.

BankUnited operates as a federally regulated bank holding company providing banking services in the United States, directly falling under the definition of financial institutions specified in 31 USC §5312(a)(2) that must comply with OFAC reporting requirements for Russian sovereign assets. As a banking institution, it would be subject to the mandatory reporting obligations for any Russian sovereign assets held and due diligence requirements for correspondent accounts. The rule focuses specifically on reporting requirements for Russian sovereign assets, which does not align with any of the company's disclosed risk factors. The company's single regulatory compliance risk is generic and unrelated to foreign asset reporting, while its primary financial risks concern interest rates, credit losses, and investment securities rather than international asset holdings or correspondent banking.

FIRST BUSEY CORP /NV/

First Busey Corporation operates as a financial holding company providing banking services, which clearly falls under the definition of financial institutions specified in 31 USC §5312(a)(2) that are subject to this rule. As a banking institution, it would be required to comply with the reporting obligations for Russian sovereign assets held in its accounts or through correspondent relationships. The rule specifically targets financial institutions holding Russian sovereign assets or maintaining correspondent banking relationships with foreign financial institutions. The company's risk factors focus on general economic conditions, competition, and operational risks in the retail sector, with no mention of international banking operations, correspondent accounts, or exposure to Russian sovereign assets.

CITIZENS FINANCIAL GROUP INC/RI

Citizens Financial Group operates as a financial institution that takes deposits and makes loans, directly falling under the categories specified in 31 USC 5312(a)(2) for financial institutions required to report Russian sovereign assets. The company's core banking operations, including maintaining correspondent accounts and handling international financial transactions, align with the rule's requirements for due diligence and reporting of such assets. The rule specifically targets financial institutions holding Russian sovereign assets or maintaining correspondent accounts for foreign financial institutions, which does not align with the company's disclosed generic regulatory and operational risks. The company's risk factors mention general regulatory supervision and business strategy execution without any indication of exposure to Russian assets, international correspondent banking, or OFAC compliance requirements.

FB Financial Corp

FB Financial Corp operates as a bank through its FirstBank subsidiary, which directly qualifies as a financial institution under the rule's scope. The company's banking services likely involve maintaining correspondent accounts and holding various assets, making it subject to the mandatory reporting requirements for Russian sovereign assets. The company's disclosed risk factors focus entirely on dividend restrictions and capital requirements compliance, which are unrelated to the OFAC reporting requirements for Russian sovereign assets. There is no mention of foreign asset reporting, international banking relationships, or sanctions compliance risks in the company's risk profile.

FIRST CITIZENS BANCSHARES INC /DE/

First Citizens BancShares operates as a major financial institution with commercial banking segments that maintain correspondent accounts and handle international financial transactions, directly falling under the rule's jurisdiction for financial institutions holding or potentially holding Russian sovereign assets. The company's risk-based capital adequacy processes and compliance infrastructure align with the due diligence and reporting requirements mandated by the OFAC rule. The rule focuses exclusively on financial reporting requirements for Russian sovereign assets and correspondent banking relationships, which has no alignment with the company's single identified risk factor of cybersecurity threats. There is no overlap between the regulatory compliance obligations for asset reporting and the company's technology security concerns.

FIRST HAWAIIAN, INC.

First Hawaiian, Inc. operates as a financial institution providing banking and trust services, directly aligning with the rule's scope targeting financial institutions holding Russian sovereign assets or maintaining correspondent accounts. As a bank, it would be subject to the reporting requirements if it holds such assets or engages in correspondent banking relationships involving foreign financial institutions. The rule focuses specifically on regulatory compliance requirements for reporting Russian sovereign assets, which does not align with the company's disclosed risk factors that primarily concern financial performance, operational costs, and market competition. The company's single regulatory compliance risk is generic and not specific to foreign asset reporting or OFAC requirements, indicating minimal relevance.

FIRST INTERSTATE BANCSYSTEM INC

First Interstate Bancsystem is a financial institution that operates correspondent banking services and maintains accounts for foreign financial institutions, directly falling under the rule's jurisdiction requiring due diligence and reporting of Russian sovereign assets. As a bank holding company with international financial operations, it would be subject to the mandatory reporting requirements for any Russian sovereign assets it holds or processes. The rule focuses on mandatory reporting of Russian sovereign assets and correspondent banking due diligence, which does not align with the company's disclosed risks of interest rate fluctuations and liquidity/capital constraints. There is minimal overlap as the rule addresses foreign asset compliance rather than domestic financial market or capital adequacy risks.

FULTON FINANCIAL CORP

Fulton Financial Corp operates as a financial institution holding company with multiple banking subsidiaries, placing it directly within the scope of financial institutions required to report Russian sovereign assets under this OFAC rule. The company's core business of maintaining correspondent accounts and holding various financial assets aligns precisely with the reporting requirements for identifying and disclosing Russian sovereign assets. The rule focuses specifically on reporting requirements for Russian sovereign assets held by financial institutions, which does not align with any of the company's disclosed risk factors related to dividend dependence, equity compensation, or regulatory dividend restrictions. The company's risk profile shows no indication of exposure to international asset holdings, correspondent banking, or foreign asset compliance issues that would be affected by this rule.

HUNTINGTON BANCSHARES INC /MD/

Huntington Bancshares operates as a comprehensive financial institution offering commercial banking, treasury management, foreign exchange services, and correspondent banking relationships, all of which fall directly under the rule's jurisdiction for reporting Russian sovereign assets. The company's financial services operations align perfectly with the requirements affecting financial institutions specified in 31 USC §5312(a)(2) and those maintaining correspondent accounts for foreign financial institutions. The rule focuses specifically on reporting requirements for Russian sovereign assets held by financial institutions, which does not directly align with any of the company's disclosed risk factors. While the company has one regulatory compliance risk identified, it appears to be general in nature rather than specific to foreign asset reporting or OFAC requirements.

JPMORGAN CHASE & CO

JPMorgan Chase operates as a major global financial institution with extensive correspondent banking relationships, investment banking services, and asset management operations that would directly handle Russian sovereign assets. The company's core business activities in commercial banking, investment banking, and financial transaction processing place it squarely within the scope of financial institutions required to report Russian sovereign assets under this OFAC rule. The rule focuses on mandatory reporting of Russian sovereign assets by financial institutions, which does not align with the company's disclosed risk factors that primarily concern fair value estimation, consolidation of VIEs, and accounting standards compliance. There is minimal overlap as the company's regulatory compliance risks (28 identified) are generic and not specific to foreign asset control or sovereign asset reporting.

KEYCORP /NEW/

KeyCorp operates as a bank holding company providing comprehensive financial services, directly falling under the definition of financial institutions specified in 31 USC 5312(a)(2) that must report Russian sovereign assets. As a major banking institution, it likely maintains correspondent accounts for foreign financial institutions and could hold Russian sovereign assets, triggering mandatory reporting requirements under this rule. The rule focuses on mandatory reporting of Russian sovereign assets by financial institutions, which does not align with the company's disclosed risk factors that are primarily cybersecurity and technology-related. There is no mention of international asset holdings, correspondent banking, or foreign asset reporting in the company's risk profile.

M&T BANK CORP

M&T Bank Corp operates as a commercial bank and maintains correspondent banking relationships, directly falling under the rule's jurisdiction for financial institutions holding Russian sovereign assets or maintaining correspondent accounts for foreign financial institutions. The bank's institutional services segment would be particularly affected by the reporting requirements for sovereign asset holdings. The rule's mandatory reporting requirements for Russian sovereign assets align minimally with the company's single regulatory compliance risk factor, but the specific focus on foreign asset control and international banking relationships does not match the company's broader regulatory change concerns. The company's risk profile shows no specific exposure to international sanctions, correspondent banking, or Russian asset holdings that would create material alignment.

RAYMOND JAMES FINANCIAL INC

Raymond James Financial operates a banking segment that provides traditional banking services, making it a financial institution subject to OFAC reporting requirements for Russian sovereign assets. The company's correspondent banking relationships and asset management activities would require due diligence and reporting under this rule. The rule's focus on mandatory reporting of Russian sovereign assets and correspondent banking due diligence does not align with the company's disclosed risk factors of cybersecurity vulnerabilities, model risk, and general compliance risk. The company's compliance risk is generic and not specifically related to foreign asset control or international banking regulations, showing minimal relevance to this specialized OFAC reporting requirement.

STIFEL FINANCIAL CORP

Stifel Financial Corp operates as a financial holding company with banking, broker-dealer, and asset management subsidiaries, placing it squarely within the definition of financial institutions covered by this rule. The company's core activities in banking and asset management would require compliance with the mandatory reporting requirements for Russian sovereign assets, including due diligence for correspondent accounts. The rule's mandatory reporting requirements for Russian sovereign assets align moderately with the company's 'Legal and Regulatory Non-Compliance' risk, as failure to comply could result in regulatory sanctions and penalties. However, the specific focus on Russian assets and correspondent banking relationships does not directly match the company's broader operational and cybersecurity risk profile.

SIMMONS FIRST NATIONAL CORP

Simmons First National Corp operates as a banking and financial services institution, which directly falls under the definition of financial institutions specified in 31 USC §5312(a)(2) that are targeted by this rule. As a financial holding company providing banking services, it would be required to comply with the mandatory reporting requirements for Russian sovereign assets and exercise due diligence on correspondent accounts. The rule focuses specifically on reporting requirements for Russian sovereign assets held by financial institutions, which does not align with any of the company's disclosed risk factors. The company's risks are primarily related to credit losses, economic conditions, accounting valuations, goodwill impairment, and tax interpretations, none of which involve foreign asset reporting or OFAC compliance.

StoneX Group Inc.

StoneX operates as a financial institution with correspondent clearing services and FX prime brokerage, directly falling under the rule's jurisdiction for financial institutions maintaining correspondent accounts. The company's institutional segment handles foreign currency transactions and international clearing services, creating potential exposure to Russian sovereign assets through correspondent banking relationships. The rule focuses exclusively on financial institutions holding Russian sovereign assets and correspondent banking relationships, while the company's only disclosed risk is cybersecurity threats with no mention of financial services operations, international banking, or asset management activities. There is no overlap between the regulatory reporting requirements for Russian assets and the company's cybersecurity risk profile.

SYNOVUS FINANCIAL CORP

Synovus Financial Corp operates as a financial institution providing banking services including correspondent banking relationships, which directly falls under the rule's jurisdiction requiring reporting of Russian sovereign assets. As a regional bank with international banking capabilities, it would be subject to the due diligence and reporting requirements for any Russian sovereign assets held. The rule's mandatory reporting requirements for Russian sovereign assets and correspondent banking due diligence could potentially increase compliance costs, which might indirectly relate to the company's risk of 'changes in the cost and availability of funding.' However, this connection is extremely weak as the company's risk factors are generic banking concerns rather than specific to asset reporting or international sanctions compliance.

WSFS FINANCIAL CORP

WSFS Financial Corp operates as a financial institution providing banking services including correspondent banking relationships, which directly falls under the rule's jurisdiction requiring due diligence and reporting of Russian sovereign assets. As a federally regulated bank, it would be subject to OFAC requirements and likely maintains accounts that could hold foreign assets subject to this reporting mandate. The rule focuses specifically on reporting requirements for Russian sovereign assets held by financial institutions, which does not align with any of the company's disclosed risk factors. The company's risks center around credit loss provisioning, operational costs, and commercial real estate exposure, none of which relate to foreign asset reporting or OFAC compliance.

BANK OF AMERICA CORP /DE/

Bank of America is a major financial institution that operates correspondent banking services and maintains international accounts, directly falling under the rule's requirements to report Russian sovereign assets. As a global bank with extensive foreign financial relationships, it would be required to exercise due diligence and report any such assets held in its accounts. The rule focuses on mandatory reporting of Russian sovereign assets by financial institutions, which does not align with any of the company's disclosed risk factors related to goodwill impairment, tangible assets valuation, contingent liabilities, non-GAAP measures, or accounting principles compliance. The company's risk profile centers on financial reporting and valuation issues rather than international asset reporting or sanctions compliance.

BANC OF CALIFORNIA, INC.

Banc of California operates as a bank holding company for a national association bank, placing it squarely within the definition of financial institutions targeted by this rule. As a banking institution, it likely maintains correspondent accounts and handles foreign financial transactions where Russian sovereign assets could be present, directly aligning with the reporting requirements. The rule focuses specifically on reporting requirements for Russian sovereign assets, which does not align with any of the company's disclosed risk factors. The company's single regulatory compliance risk is generic and not specific to foreign asset reporting or OFAC requirements, indicating minimal relevance to this particular rule.

BANCFIRST CORP /OK/

BancFirst Corporation operates as a commercial bank, which falls directly under the definition of financial institutions specified in 31 USC §5312(a)(2) that are subject to this rule. As a commercial banking institution, it likely maintains correspondent accounts and holds various assets that could include Russian sovereign assets, making it subject to the mandatory reporting requirements. The rule directly aligns with the company's OFAC Sanctions Compliance risk, which is explicitly identified as a regulatory risk involving financial, legal, and reputational damages. The mandatory reporting requirements for Russian sovereign assets create immediate compliance obligations that match this specific risk factor.

BlackRock, Inc.

BlackRock operates as a major global financial institution that manages trillions in assets, including sovereign wealth funds and international investments, placing it directly within the scope of financial institutions required to report Russian sovereign assets. The company's extensive correspondent banking relationships and international asset management activities align perfectly with the rule's requirements for due diligence and reporting on foreign financial institution accounts. The rule focuses on mandatory reporting of Russian sovereign assets and correspondent banking due diligence, which does not align with any of the company's disclosed risk factors. The company's risks center on interest rates, market performance, acquisition integration, fee declines, and foreign exchange impacts - none of which relate to regulatory compliance reporting or Russian asset exposure.

BOK FINANCIAL CORP

BOK Financial operates as a full-service financial institution with commercial banking, consumer banking, and wealth management services, placing it directly within the scope of financial institutions required to report Russian sovereign assets under the REPO Act. The company's correspondent banking relationships and asset custody services in wealth management create clear operational alignment with the rule's reporting requirements for institutions holding or managing foreign assets. The rule's focus on mandatory reporting of Russian sovereign assets has minimal alignment with BOK Financial's disclosed risk factors, which center on asset quality deterioration, competitive pressures, cybersecurity, regulatory approvals, and interest margins. While the company identifies regulatory compliance risks generally, there is no specific mention of foreign asset reporting or international sanctions compliance that would directly correlate with this rule's requirements.

COMERICA INC /NEW/

Comerica operates as a major financial institution with commercial and retail banking operations, including correspondent banking services and foreign exchange activities, which directly fall under the rule's jurisdiction requiring reporting of Russian sovereign assets. The company's existing compliance with anti-money laundering regulations and international banking relationships indicates strong operational alignment with the rule's due diligence and reporting requirements. The rule focuses exclusively on financial institutions holding Russian sovereign assets and correspondent banking relationships, while the company's only disclosed risk is cybersecurity threats. There is no overlap between the regulatory reporting requirements for Russian assets and the company's technology cybersecurity risk profile.

COLUMBIA BANKING SYSTEM, INC.

Columbia Banking System operates as a financial institution that maintains correspondent accounts and handles international banking relationships, directly falling under the rule's jurisdiction for financial institutions holding Russian sovereign assets or maintaining correspondent accounts for foreign financial institutions. The company's core banking operations align perfectly with the reporting requirements and due diligence obligations specified in the rule. The rule focuses specifically on reporting requirements for Russian sovereign assets, which does not align with any of the company's disclosed risk factors. The company's single regulatory compliance risk is generic and not specific to foreign asset reporting or OFAC requirements, showing minimal relevance to this specialized financial regulation.

FIRST HORIZON CORP

First Horizon Corp operates as a regional bank holding company with significant financial institution operations, including correspondent banking services and international financial activities that would fall under the rule's jurisdiction. The company's core business as a financial institution directly aligns with the reporting requirements for Russian sovereign assets and correspondent account due diligence. The rule's focus on Russian sovereign asset reporting and correspondent banking due diligence has minimal alignment with the company's disclosed risk factors, which center on domestic financial pressures like net interest margin compression and mortgage demand decline. The company's single regulatory compliance risk is generic and doesn't specifically address international asset reporting or OFAC requirements.

FIFTH THIRD BANCORP

Fifth Third Bancorp operates as a financial institution offering banking and financial services, which directly falls under the rule's jurisdiction requiring financial institutions to report Russian sovereign assets. As a major bank, it likely maintains correspondent accounts and handles international assets that could include Russian sovereign holdings, making it subject to the reporting requirements. The rule focuses specifically on reporting requirements for Russian sovereign assets, which does not align with the company's disclosed credit, liquidity, and operational risks. The company's single regulatory compliance risk is related to dividend constraints, not asset reporting obligations for foreign sovereign holdings.

FLAGSTAR FINANCIAL, INC.

Flagstar Financial operates as a financial institution holding company for Flagstar Bank N.A., directly falling under the rule's jurisdiction for financial institutions specified in 31 USC 5312(a)(2). The company's banking operations, including correspondent banking relationships and asset holdings, would require compliance with the mandatory reporting requirements for Russian sovereign assets. The rule's mandatory reporting requirements for Russian sovereign assets align moderately with the company's identified regulatory compliance risks, specifically increased compliance costs and operational restrictions. However, the company's risk profile shows broader financial and market risks that are not directly addressed by this specific asset-focused reporting requirement.

FIRST MERCHANTS CORP

First Merchants Corp operates as a banking and financial services institution, which directly falls under the rule's scope targeting financial institutions holding Russian sovereign assets or maintaining correspondent accounts. As a bank, it would be subject to the mandatory reporting requirements and due diligence obligations for identifying and reporting such assets. The rule's mandatory reporting requirements for Russian sovereign assets align minimally with the company's regulatory compliance risk factor, but this represents only one of seven identified risks. The company's primary financial, operational, and cybersecurity risks show no meaningful connection to the specific asset reporting obligations imposed by this Ukraine-focused regulation.

Interactive Brokers Group, Inc.

Interactive Brokers operates as a global electronic broker providing custody of securities and foreign exchange services, directly aligning with the rule's requirements for financial institutions holding or managing assets. The company's role in automated trade execution and custody services means it would likely handle Russian sovereign assets and maintain correspondent accounts, triggering mandatory reporting obligations under this OFAC rule. The rule focuses on mandatory reporting of Russian sovereign assets by financial institutions, which does not align with any of the company's identified risk factors. The company's risks center around trading volumes, interest income, commission structures, technology dependence, and regulatory fee pass-through, none of which relate to foreign asset reporting or correspondent banking due diligence requirements.

INTERNATIONAL BANCSHARES CORP

International Bancshares Corp operates as a bank holding company with subsidiary banks providing commercial and retail banking services, making it clearly subject to financial institution reporting requirements under this rule. The company's banking operations would likely involve correspondent accounts and handling of foreign assets, directly falling under the rule's jurisdiction for identifying and reporting Russian sovereign assets. The rule's focus on mandatory reporting of Russian sovereign assets has minimal alignment with the company's disclosed risk factors, which center on loan loss allowances, competition, liquidity, real estate values, and dividend constraints. While the company identifies regulatory compliance as a risk category, this specific reporting requirement for foreign assets does not directly address any of their stated operational or financial vulnerabilities.

NORTHERN TRUST CORP

Northern Trust Corp operates as a major financial institution providing custody, asset servicing, and banking services, directly falling under the rule's jurisdiction for financial institutions holding or managing assets. The company's core business of maintaining custody accounts and correspondent banking relationships aligns precisely with the reporting requirements for Russian sovereign assets. The rule specifically targets financial institutions holding Russian sovereign assets or maintaining correspondent banking relationships with foreign financial institutions. The company operates in the consumer goods sector with no financial services operations, and its disclosed risk factors focus on supply chain, consumer demand, and market competition rather than financial asset reporting or international banking compliance.

PNC FINANCIAL SERVICES GROUP, INC.

PNC Financial Services Group is a major U.S. financial institution that operates correspondent banking services and maintains accounts for foreign financial institutions, directly falling under the rule's jurisdiction for reporting Russian sovereign assets. As a large bank with international operations, it would be required to exercise due diligence and report any such assets held in its accounts. The rule's focus on mandatory reporting of Russian sovereign assets and correspondent banking due diligence has minimal alignment with the company's disclosed risk profile, which emphasizes operational, financial derivatives, and information security risks without specific mention of international asset reporting or correspondent banking compliance.

REGIONS FINANCIAL CORP

Regions Financial Corp operates as a comprehensive financial institution offering commercial banking, retail banking, and wealth management services, directly falling under the rule's jurisdiction for financial institutions holding Russian sovereign assets or maintaining correspondent accounts. The company's extensive securities portfolio, international banking relationships, and correspondent banking services create significant exposure to the reporting requirements for Russian sovereign assets. The rule's focus on mandatory reporting of Russian sovereign assets and correspondent banking due diligence has minimal alignment with the company's disclosed risk factors, which primarily address market conditions, credit losses, and cybersecurity rather than specific asset reporting or international sanctions compliance.

TEXAS CAPITAL BANCSHARES INC/TX

Texas Capital Bancshares operates as a financial institution with commercial banking, correspondent banking relationships, and international financial services that would likely involve holding or processing foreign sovereign assets. The company's core banking operations and financial services directly align with the rule's requirements for financial institutions to report Russian sovereign assets and exercise due diligence on correspondent accounts. The rule's focus on mandatory reporting of Russian sovereign assets and correspondent banking due diligence has minimal alignment with the company's disclosed risk factors, which center on credit losses, debt management, and capital position without mentioning international asset holdings or correspondent banking activities. The only potential indirect connection is through the general regulatory compliance risk, but this is too vague to indicate specific relevance to this OFAC reporting requirement.

WESTERN ALLIANCE BANCORPORATION

Western Alliance Bancorporation operates as a financial institution that provides deposit services and maintains correspondent banking relationships, directly falling under the rule's jurisdiction for reporting Russian sovereign assets. The company's core banking operations align with the requirements to identify and report such assets held in accounts or through correspondent relationships. The rule focuses on mandatory reporting of Russian sovereign assets by financial institutions, which does not align with the company's disclosed risk factors centered on CRE market deterioration, charge-offs, FDIC assessments, CECL transition, and foreclosure issues. There is minimal overlap as the company's single regulatory compliance risk (CECL transition) relates to accounting standards rather than foreign asset reporting requirements.

WINTRUST FINANCIAL CORP

Wintrust Financial Corp operates as a financial institution offering banking, commercial lending, and wealth management services, which directly aligns with the rule's targeting of financial institutions holding Russian sovereign assets or maintaining correspondent accounts. As a banking entity, it would be subject to the mandatory reporting requirements and due diligence obligations for identifying and reporting such assets. The rule focuses on mandatory reporting of Russian sovereign assets and correspondent banking due diligence, which does not align with the company's disclosed risk factors related to interest rates, asset-liability management, and inflation. The company's risk profile shows no mention of foreign asset compliance, international banking exposure, or sovereign asset holdings that would be affected by this specific OFAC reporting requirement.

ZIONS BANCORPORATION, NATIONAL ASSOCIATION /UT/

Zions Bancorporation operates as a financial institution providing banking services, which directly falls under the rule's jurisdiction requiring financial institutions to report Russian sovereign assets. The company maintains correspondent accounts and handles international banking relationships, making it subject to the due diligence and reporting requirements for identifying and reporting such assets. The rule focuses on reporting requirements for Russian sovereign assets and correspondent banking relationships, which does not align with the company's disclosed risk factors of credit quality deterioration, cybersecurity threats, operational disruptions, talent retention, or counterparty concentration. There is minimal overlap as the rule addresses regulatory compliance risks not identified in the company's risk profile.