Does the CBW Act Directive prohibit participation in the secondary market for Russian sovereign debt?

OFAC's answer

No, the [CBW Act Directive](https://ofac.treasury.gov/media/33956/download?inline) does not prohibit U.S. banks from participating in the secondary market for Russian sovereign debt. However, independent of the CBW Act Directive, OFAC has imposed prohibitions on certain Russia-related sovereign entities subject to the CBW Act Directive, pursuant to Russia-related directives under [Executive Order (E.O.) 14024](https://ofac.treasury.gov/media/57936/download?inline) (see [FAQ 1000](https://ofac.treasury.gov/faqs/1000)). Date Updated: March 02, 2022

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