OFAC FAQ #971 · Russian Harmful Foreign Activities Sanctions
Are the prohibitions of Directive 2 under Executive Order (E.O.) 14024, “Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions” (Russia-related CAPTA Directive) limited to transactions denominated in U.S. dollars?
OFAC's answer
No. The prohibitions of the [Russia-related CAPTA Directive](https://ofac.treasury.gov/media/918471/download?inline)apply with respect to any currency. For example, a foreign branch of a U.S. financial institution may not open or maintain a correspondent account for or on behalf of, or process a transaction involving, a foreign financial institution determined to be subject to the prohibitions of the Russia-related CAPTA Directive, even if that account is denominated in a currency other than U.S. dollars, such as euros.