Retention Date: 03/01/24
This emergency message (EM) provides guidance on the Supplemental Security Income (SSI) income and resource treatment of Russian pensions and resources, which may be suspended or inaccessible due to the war in Ukraine and resulting U.S. economic sanctions against Russia.
In response to the Russian invasion of Ukraine, the United States imposed several economic sanctions against Russia’s largest financial institutions on February 24, 2022. The economic sanctions froze Russian assets from interfacing with the U.S. financial system and barred U.S. persons from conducting business with sanctioned Russian financial institutions. Following sanctions, Russia implemented measures that further restricted the transfer of securities and assets with the U.S. As a result, SSI applicants, recipients, and deemors who receive Russian pensions or have resources in Russia may be unable to access payments and resources. Furthermore, obtaining documentation and evidence to support income and resource allegations may not be possible.
1. Policy for developing and documenting suspended or inaccessible Russian pensions
|Intended Audience:||All RCs/ARCs/ADs/FOs/TSCs/PSCs/OCO/OCO-CSTs/OHO/OARO|
|Originating Office:||ORDP OISP|
|Title:||Developing Russian Pensions and Resources that are Restricted or Inaccessible due to the Russo-Ukrainian War|
|Type:||EM - Emergency Messages|
|Program:||Title XVI (SSI)|
|Link To Reference:||See Reference at the end of this EM|
When an applicant, recipient, or deemor alleges the suspension of, or inability to access, a Russian pension due to U.S. sanctions or counter Russian restrictions:
2. Policy for developing and documenting inaccessible Russian resources
· Request proof of suspension of or inability to access the Russian pension (e.g., a letter or notification from the financial institution, or bank statements showing pension deposits in prior months but not in months where the individual alleges the pension deposits have stopped).
· If evidence is unavailable, document the allegation on a report of contact (i.e., Report of Contact page in the Consolidated Claims Experience (CCE) or SSA-5002) or on a signed Person Statement in CCE or SSA-795. Include the specific pension(s) and when the pension(s) were suspended or became inaccessible.
· Inform the individual that they are responsible for reporting to SSA when the pension (or access to it) resumes.
· On the Pension, Annuity, Retirement, or Disability Payment Page in SSI Claims, enter $0.00 in the ALLEGED AMOUNT field for the month, per the allegation, the pension payment became inaccessible.
· Identify the pension by entering RUSS in the Case Characteristics Code (CG) field on the SSR Special Messages page in CCE or via 1719B for non-MSSICS cases. (See SM 01301.785, SM 01601.460, and MS 08125.010).
· On the Development Worksheet page in CCE, in the ISSUE field enter PENSION, in the REMARKS field enter RUSSIAN PMTS, and set a tickle date for one year to monitor and develop for the resumption of the pension payment.
NOTE: During a redetermination, request proof of suspension of, or inability to access, the Russian pension. Accept the individual’s allegation if evidence is unavailable.
The combination of U.S. sanctions against Russia and Russian policies restricting securities and asset transfers outside of Russia may prevent individuals living in the U.S. from accessing Russian resources. For example, individuals may not be able to:
· access money they hold in Russian banks,
· transfer money out of Russian banks to U.S. based or foreign financial institutions,
· sell or transfer their real property in Russia, or
· access proceeds from the sale or conversion of their resources.
Lack of access renders the item an asset that does not meet the definition of a resource per SI 01110.100B.
When an applicant, recipient, or deemor alleges owning resources in Russia AND they allege not being able to access them due to sanctions or Russian policies, do the following:
· Request proof of inability to access resources (e.g., a letter or notification from financial institution showing no access).
· If evidence is unavailable, accept the individual’s allegation on a report of contact (i.e., Report of Contact page in CCE or SSA-5002) or on a signed Person Statement in CCE or SSA-795. Include the specific resources and when the resources became inaccessible.
· On the appropriate resource page in SSI Claims, enter $0.00 in the ALLEGED VALUE field for the month after the allegation the resource became inaccessible.
· Identify the asset by entering RUSS in the Case Characteristics Code (CG) field on the SSR Special Messages page in CCE or via 1719B for non-MSSICS cases. (See SM 01301.785, SM 01601.460, and MS 08125.010).
· On the Development Worksheet page in CCE, in the ISSUE field enter RUS ASSET, in the REMARKS field enter DEV RUSSIAN ASSET, and set a tickle date for one year to monitor and develop the access issue. Inform the individual that they are responsible for reporting to SSA when they regain access the resource.
For allegations concerning real property in Russia, follow development instructions in SI 01140.100J to determine whether a legal bar prevents sale or transfer of the property. Accept the allegation when evidence is unavailable.
NOTE: During a redetermination, request proof of inability to access Russian resources. Accept the individual’s allegation if evidence is unavailable. For assets that have become accessible during the period of review, develop ownership and resource value back to the month after the month access was returned.
Please direct all program-related and technical questions to your Regional Office (RO) support staff or Program Service Center (PSC) Operations Analysis (OA) staff. RO support staff or PSC OA staff may refer questions, concerns, or problems to their Central Office contacts.
SI 00810.030 When Income is Counted
SI 01110.100 Distinction Between Assets and Resources
SI 01110.115 Assets That Are Not Resources
SI 01140.100 Non-Home Real Property
MS 08122.004 Development Worksheet
MS 08122.008 Person Statement
MS 08122.010 Report of Contact
MS 08125.010 SSR Special Messages
SM 01301.785 Case Related Data (CG)
SM 01601.460 Case Redetermination Data (CRZD)
EM-22049 - Developing Russian Pensions and Resources that are Restricted or Inaccessible due to the Russo-Ukrainian War - 09/09/2022