Does the prohibition on dealing in new equity of entities subject to Directive 1 apply to transactions in which those entities are not the issuer of the equity?

OFAC's answer

U.S. persons are not prohibited from dealing in new equity with an entity subject to [Directive 1](https://ofac.treasury.gov/media/8696/download?inline) if the entity is not the issuer of the equity. For instance, U.S. persons are not prohibited from transacting with an entity subject to Directive 1 in support of new equity where the entity subject to Directive 1 is the underwriter of the equity and not the issuer.

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