OFAC FAQ #965 · Russian Harmful Foreign Activities Sanctions

How does Directive 1A under Executive Order (E.O.) 14024, “Prohibitions Related to Certain Sovereign Debt of the Russian Federation” (Russia-related Sovereign Debt Directive) change prohibitions relating to U.S. financial institution dealings in Russian sovereign debt pursuant to Directive 1 under E.O. 14024 of April 15, 2021?

OFAC's answer

Directive 1 under [E.O. 14024](https://ofac.treasury.gov/media/57936/download?inline) of April 15, 2021 imposed prohibitions on participation in the primary market for ruble or non-ruble denominated bonds issued by, or the lending of ruble or non-ruble denominated funds to, the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation. The [Russia-related Sovereign Debt Directive](https://ofac.treasury.gov/media/918731/download?inline) replaces and supersedes Directive 1 under E.O. 14024 of April 15, 2021. It expands upon the existing prohibitions to also prohibit, as of March 1, 2022 , participation in the secondary market for ruble or non-ruble denominated bonds issued by these entities after March 1, 2022. Please see [FAQ 888](https://ofac.treasury.gov/faqs/888) for additional details on the effective dates of these prohibitions. The Russia-related Sovereign Debt Directive also includes technical revisions to the definition of “U.S. financial institution” to expand the definition. Independent of the Russia-related Sovereign Debt Directive, OFAC has imposed prohibitions on certain Russia-related entities subject to the Russia-related Sovereign Debt Directive, pursuant to Russia-related directives under E.O. 13883 and E.O. 14024. Date Updated: March 02, 2022

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