OFAC FAQ #988 · Russian Harmful Foreign Activities Sanctions

Does Russia-related Directive 3 under Executive Order (E.O.) 14024, “Prohibitions Related to New Debt and Equity of Certain Russia-related Entities” (Russia-related Entities Directive) prohibit U.S. persons from engaging in all activities with entities subject to it?

OFAC's answer

No. The [Russia-related Entities Directive](https://ofac.treasury.gov/media/918476/download?inline) prohibits U.S. persons from engaging in only certain activities related to new debt of longer than 14 days maturity or new equity of the entities listed in Annex 1 to the Russia-related Entities Directive, or of entities otherwise determined to be subject to the prohibitions of the Russia-related Entities Directive, as explained in [FAQ 984](https://ofac.treasury.gov/faqs/984). Please see [FAQ 985](https://ofac.treasury.gov/faqs/985) regarding the applicability of OFAC’s 50 Percent Rule with respect to this directive. Some entities determined to be subject to the prohibitions of the Russia-related Entities Directive may also be subject to additional prohibitions under other sanctions authorities, such as additional directives under [E.O. 14024](https://ofac.treasury.gov/media/57936/download?inline) or [E.O. 13662](https://ofac.treasury.gov/media/5961/download?inline). It is important to note that each directive operates independently of the others. For example, if a transaction involves a person subject to two separate directives, a U.S. person engaging in that transaction must comply with both directives.

Related programs

russia

Related FAQs

Read this FAQ on the OFAC site ↗