OFAC FAQ #372 · Ukraine-/Russia-related Sanctions
Do Directives 1, 2, and 3 prohibit U.S. persons from entering into derivatives contracts linked to new debt or new equity issued by the entities subject to the Directives?
OFAC's answer
On November 28, 2017, OFAC issued [General License 1B](https://ofac.treasury.gov/media/8971/download?inline), which continues to authorize certain transactions involving derivative products that would otherwise be prohibited pursuant to Directives 1, 2, or 3. [General License 1B](https://ofac.treasury.gov/media/8971/download?inline) replaced and superseded General License No. 1A, dated September 12, 2014.