OFAC FAQ #1003 · Russian Harmful Foreign Activities Sanctions
Are transactions where the Central Bank of the Russian Federation, National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation serves solely as the operator of a clearing and settlement system authorized?
OFAC's answer
Yes. Please see [General License 14](https://ofac.treasury.gov/media/918896/download?inline) and [FAQ 999](https://ofac.treasury.gov/faqs/999).