OFAC FAQ #986 · Russian Harmful Foreign Activities Sanctions
What constitutes debt or equity for purposes of Directive 3 under Executive Order (E.O.) 14024, “Prohibitions Related to New Debt and Equity of Certain Russia-related Entities” (Russia-related Entities Directive)?
OFAC's answer
The term “debt” includes bonds, loans, extensions of credit, loan guarantees, letters of credit, drafts, bankers acceptances, discount notes or bills, or commercial paper. The term “equity” includes stocks, share issuances, depositary receipts, or any other evidence of title or ownership.