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I have an inherited investment trust account from my father, who died in 2019, which included approximately 10 shares of Lukoil stock, which has subsequently been sanctioned by the US Government. I am in the process of transferring management of that trust from Truist Bank to the Trust Management Department of Bank of America.

Today, I was informed that Bank of America's Trust Department has refused to accept the transfer of the trust because of those 10 shares of sanctioned stock. They are, as far as I can tell now, virtually worthless. Truist has offered to place them in an escrow-type account, but Bank of America contends that they will still be part of the Trust in toto, and will not accept the transfer.

Is there a process by which I can dispose of those stocks legally? I've been told I can not sell them, but can they be legally disavowed, discarded, or quarantined from the rest of the trust account?

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  • Possibly related Jun 28, 2023 at 22:29
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    What do the trust documents allow the trustee(s) to do with assets? Writing the shares off and eliminating from the trust may well be an option. Or disburse those shares from the trust to the beneficiary as part of any required annual distributions.
    – Jon Custer
    Jun 29, 2023 at 17:59

2 Answers 2

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The Office of Foreign Assets Control provides instructions on how to navigate transactions involving sanctioned entities, and their instructions boil down to "you need to get our permission." If you haven't contacted OFAC, a good place to start fixing this would be to get in touch with them, explain you are looking to divest these shares, and that you need their help to navigate that process.

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From comment above (Jon)

Writing the shares off and eliminating from the trust may well be an option. Or disburse those shares from the trust to the beneficiary as part of any required annual distributions.

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