OFAC FAQ #1052 · Russian Harmful Foreign Activities Sanctions
Can U.S. persons continue to fund their subsidiaries and affiliates with projects or operations located in the Russian Federation prior to the effective dates of the new investment prohibitions of Executive Order (E.O.) 14066, E.O. 14068, or E.O. 14071 (collectively, “the respective E.O.s”)?
OFAC's answer
Yes, provided that the use of the funds by the subsidiary or affiliate is consistent with maintenance, as described in [FAQ 1050](https://ofac.treasury.gov/faqs/1050). “Maintenance” does not include the expansion of pre-existing projects or operations beyond those in effect prior to the effective dates of the respective E.O. prohibitions. Therefore, U.S. persons may not fund new or expanded projects or operations undertaken by their subsidiaries and affiliates located in the Russian Federation after the effective dates of the respective E.O. prohibitions.