Does 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), prohibit trading in the secondary markets for Russian sovereign debt?
OFAC's answer
No, the Russia-related Sovereign Transactions Directive does not prohibit trading in the secondary markets for debt or equity of the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation (collectively, “Directive 4 entities”), provided that no [Directive 4](https://ofac.treasury.gov/media/918806/download?inline) entity is a counterparty to such a transaction. Please note, however, that [Directive 1A](https://ofac.treasury.gov/media/918731/download?inline) under [E.O. 14024](https://ofac.treasury.gov/media/57936/download?inline), “Prohibitions Related to Certain Sovereign Debt of the Russian Federation” (Russia-related Sovereign Debt Directive), prohibits U.S. financial institutions from participation in the secondary market for ruble or non-ruble denominated bonds issued after March 1, 2022 by the Directive 4 entities. However, the “new investment” prohibitions of [E.O.14066](https://ofac.treasury.gov/media/919111/download?inline), [E.O. 14068](https://ofac.treasury.gov/media/919281/download?inline), and [E.O. 14071](https://ofac.treasury.gov/media/922081/download?inline) prohibit U.S. persons from purchasing debt and equity securities issued by an entity in the Russian Federation. Please see [FAQ 1054](https://ofac.treasury.gov/faqs/1054). Date Updated: May 19, 2023