What sanctions are applicable to the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation?

OFAC's answer

The Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation are subject to several restrictions under the following directives: - Effective February 28, 2022, [Directive 4](https://ofac.treasury.gov/media/918806/download?inline) under Executive Order (E.O.) 14024, “Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation,” as amended (Russia-related Sovereign Transactions Directive), prohibits U.S. persons from engaging in any transaction involving these entities, including any transfer of assets to such entities or any foreign exchange transaction for or on behalf of such entities. The Russia-related Sovereign Transactions Directive was amended on May 19, 2023 to include a reporting requirement. ([see FAQ 998](https://ofac.treasury.gov/faqs/998)) - Pursuant to [Directive 1A](https://ofac.treasury.gov/media/918731/download?inline) under E.O. 14024, “Prohibitions Related to Certain Sovereign Debt of the Russian Federation” (Russia-related Sovereign Debt Directive), the following activities by a U.S. financial institution are prohibited: - As of June 14, 2021, participation in the primary market for ruble or non-ruble denominated bonds issued after June 14, 2021 by the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation; - As of June 14, 2021, lending ruble or non-ruble denominated funds to the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation; and - As of March 1, 2022, participation in the secondary market for ruble or non-ruble denominated bonds issued after March 1, 2022 by the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation (see [FAQ 888](https://ofac.treasury.gov/faqs/888)). - Effective August 19, 2019, the [Russia-Related Directive (the “CBW Act Directive”)](https://ofac.treasury.gov/media/33956/download?inline) prohibits U.S. banks from participating in the primary market for non-ruble denominated bonds issued by the Russian sovereign and also prohibits U.S. banks from lending non-ruble denominated funds to the Russian sovereign. The CBW Act Directive defines the term “Russian sovereign” as any ministry, agency, or sovereign fund of the Russian Federation, including the Central Bank of the Russian Federation, the National Wealth Fund, and the Ministry of Finance of the Russian Federation (see [FAQs 675](https://ofac.treasury.gov/faqs/675)and [676](https://ofac.treasury.gov/faqs/676)). The [Russia-related Sovereign Transactions Directive](https://ofac.treasury.gov/media/918806/download?inline) includes prohibitions more expansive than the Russia-related Sovereign Debt Directive and the CBW Act Directive; however, it is important to note that each directive operates independently of the others and may have different effective dates. Transactions involving these entities must comply with all three directives described above. Date Updated: May 19, 2023

Related programs

Related FAQs

• #675How does OFAC implement sanctions related to U.S. bank loans imposed on Russia pursuant to the CBW Act?
• #676What do the CBW Act Directive terms “U.S. bank” and “Russian sovereign” mean?
• #888What does Directive 1A under Executive Order (E.O.) 14024, “Prohibitions Related to Certain Sovereign Debt of the Russian Federation” (Russia-related Sovereign Debt Directive) do?
• #998What are the requirements of Directive 4 under Executive Order (E.O.) 14024, “Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation,” as amended (Russia-related Sovereign Transactions Directive)?