OFAC amends 2 Russia General Licenses, issues 2 more, and … FAQs

(c) Except as provided in paragraph (e) of this general license, all transactions prohibited by Directive 4 under Executive Order (E.O). 14024, Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation, that are ordinarily incident and necessary to the receipt of interest, dividend, or maturity payments in connection with debt or equity of the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation issued before March 1, 2022, are authorized through 12:01 a.m. eastern daylight time, May 25, 2022.

(2) Any debit to an account on the books of a U.S. financial institution of the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation; or
(3) Any transactions otherwise prohibited by the RuHSR, including transactions involving any person blocked pursuant to the RuHSR other than the persons described in paragraph (a) of this general license, unless separately authorized.

(b) Except as provided in paragraph (c) of this general license, all transactions prohibited by Directive 4 under Executive Order (E.O). 14024, Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation, that are ordinarily incident and necessary to the wind down of derivative contracts, repurchase agreements, or reverse repurchase agreements entered into prior to 12:01 a.m. eastern standard time, March 1, 2022, that include the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation (collectively, “Directive 4 entities”) as a counterparty are authorized through 12:01 a.m. eastern daylight time, May 25, 2022.

(2) Any debit to an account on the books of a U.S. financial institution of the Directive 4 entities; or
(3) Any transactions otherwise prohibited by the RuHSR, including transactions involving any person blocked pursuant to the RuHSR other than the persons described in paragraph (a) of this general license, unless separately authorized.

1,009. Does Executive Order (E.O.) 14065 block the entire Donetsk and Luhansk oblasts?

No.  E.O. 14065 targets the so-called Donetsk People’s Republic and Luhansk People’s Republic regions of Ukraine or such other regions of Ukraine as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State (collectively, the “Covered Regions”).  U.S. persons engaging in activity outside the Covered Regions are not subject to the prohibitions in E.O. 14065.  Please see FAQ 1006 for what prohibitions apply to the Covered Regions. 

Released on 03/02/2022

Ukraine-/Russia-related Sanctions

1,008. Is there a wind-down period for the prohibitions imposed in Executive Order (E.O.) 14065?

Yes.  Through 12:01 a.m. eastern daylight time on March 23, 2022, Ukraine-related General License 17 authorizes transactions that are ordinarily incident and necessary to the wind down of transactions involving the so-called Donetsk People’s Republic (DNR) and Luhansk People’s Republic (LNR) regions of Ukraine.  Given the comprehensive nature of the sanctions on these regions, these activities include the divestiture or transfer to a non-U.S. person of a U.S. person’s share of ownership in any pre-February 21, 2022 investment located in the DNR or LNR regions of Ukraine, and the winding down of operations, contracts, or other agreements in effect prior to February 21, 2022 involving the exportation, reexportation, sale, or supply of goods, services, or technology to, or importation of any goods, services, or technology from, the DNR or LNR regions of Ukraine.

Released on 03/02/2022

Ukraine-/Russia-related Sanctions

1,007. Are U.S. persons authorized to engage in certain activity with the so-called Donetsk People’s Republic and Luhansk People’s Republic regions of Ukraine or such other regions of Ukraine as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State (collectively, the “Covered Regions)?

U.S. persons are authorized through a variety of Ukraine-related general licenses (GLs) to support certain humanitarian efforts and other activity in the Covered Regions, including transactions related to the export of food or medicine, the response to the Coronavirus Disease 2019 (COVID-19) pandemic, the official business of an international organization, or the activities of nongovernmental organizations, as well as personal remittances, telecommunications, internet services, and mail.

• GL 18 authorizes certain transactions that are ordinarily incident and necessary to:  (1)  the exportation or reexportation of agricultural commodities, medicine, medical devices, replacement parts and components for medical devices, or software updates for medical devices to the Covered Regions, or to persons in third countries purchasing specifically for resale to the Covered Regions; or (2) the prevention, diagnosis, or treatment of COVID-19 (including research or clinical studies relating to COVID-19).
• GL 19 authorizes certain transactions related to telecommunications that are ordinarily incident and necessary to the receipt or transmission of telecommunications in the Covered Regions, as well as certain transactions of common carriers involving the Covered Regions that are ordinarily incident and necessary to the receipt or transmission of mail and packages.
• GL 20 authorizes transactions for the conduct of the official business of certain international organizations and entities.  For an organizational chart of the United Nations, which lists the Programmes, Funds, and Other Entities and Bodies, as well as the Specialized Agencies and Related Organizations covered by GL 19, see the following page on the United Nations website: https://www.un.org/en/pdfs/un_system_chart.pdf.
• GL 21 authorizes certain transactions that are ordinarily incident and necessary to the transfer of noncommercial, personal remittances to or from the Covered Regions or for or on behalf of an individual ordinarily resident in the Covered Regions.  Further, GL 21 authorizes certain transactions that are ordinarily incident and necessary to maintaining, operating, or closing an account of an individual ordinarily resident in the Covered Regions.  U.S. depository institutions, U.S.-registered brokers or dealers in securities, and U.S.-registered money transmitters are authorized to process noncommercial, personal remittances pursuant to GL 21 regardless of whether the originator or beneficiary is an individual who is a U.S. person.  GL 21 is not limited to a specific method of payment and authorizes methods of payment.
• GL 22 authorizes certain transactions that are ordinarily incident and necessary to the exportation or reexportation, directly or indirectly, from the United States or by U.S. persons, wherever located, to persons in the Covered Regions, of services incident to the exchange of personal communications over the internet as well as the export of software to enable such services.  However, GL 22 does not authorize the exportation or reexportation, directly or indirectly, of services or software with knowledge or reason to know that such services or software are intended for any person whose property and interests in property are blocked. 

Released on 03/02/2022

Ukraine-/Russia-related Sanctions

1,006. What does Executive Order (E.O.) 14065 do? 

E.O. 14065 prohibits the following activities with the so-called Donetsk People’s Republic and Luhansk People’s Republic regions of Ukraine and such other regions of Ukraine as may be determined by the Secretary of the Treasury, in consultation with the Secretary of State (collectively, the “Covered Regions”):  (i) new investment in the Covered Regions by a U.S. person, wherever located; (ii) the importation into the United States, directly or indirectly, of any goods, services, or technology from the Covered Regions; (iii) the exportation, reexportation, sale, or supply, directly or indirectly, from the United States or by a U.S. person, wherever located, of any goods, services, or technology to the Covered Regions; and (iv) any approval, financing, facilitation, or guarantee by a U.S. person, wherever located, of a transaction by a foreign person where the transaction by that foreign person would be prohibited if performed by a U.S. person, or within the United States.

In addition, E.O. 14065 authorizes sanctions against persons that:  operate or have operated in the Covered Regions since February 21, 2022; are or have been a leader, official, senior executive officer, or member of the board of directors since February 21, 2022 of an entity operating in the Covered Regions; are owned or controlled by, or to have acted or purported to act for or on behalf of, directly or indirectly, any person whose property and interests in property are blocked pursuant to E.O. 14065; or have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, any person whose property and interests in property are blocked pursuant to E.O. 14065.  All property and interests in property of persons designated pursuant to E.O. 14065 that are or come within the United States or the possession or control of U.S. persons are blocked, and U.S. persons are generally prohibited from engaging in transactions with them.  Additionally, any entities 50 percent or more owned, directly or indirectly, by one or more blocked persons are also blocked. 

Released on 03/02/2022

Russian Harmful Foreign Activities Sanctions

1,005. Does Directive 4 under Executive Order (E.O.) 14024, “Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation” (Russia-related Sovereign Transactions Directive) prohibit trading in the secondary markets for Russian sovereign debt?

No, the Russia-related Sovereign Transactions Directive does not prohibit trading in the secondary markets for debt or equity of the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation (collectively, “Directive 4 entities”), provided that no Directive 4 entity is a counterparty to such a transaction.  Please note, however, that Directive 1A under E.O. 14024, “Prohibitions Related to Certain Sovereign Debt of the Russian Federation” (Russia-related Sovereign Debt Directive), prohibits U.S. financial institutions from participation in the secondary market for ruble or non-ruble denominated bonds issued after March 1, 2022 by the Directive 4 entities.  

With respect to the receipt of interest, dividend, or maturity payments made in connection with debt or equity of the Directive 4 entities, please see General License 9A and FAQ 981.

Released on 03/02/2022

Russian Harmful Foreign Activities Sanctions

1,004. Are U.S. persons required to block transactions involving entities subject to Directive 4 under Executive Order (E.O.) 14024, “Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation” (Russia-related Sovereign Transactions Directive)?

No.  Although the prohibitions of Directive 4 effectively immobilize any assets of the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation (collectively, the “Directive 4 entities”) that are held in the United States or by U.S. persons, wherever located, the directive does not impose blocking sanctions on the Directive 4 entities.  Rather, U.S. persons must reject transactions involving the Directive 4 entities, unless exempt or authorized by OFAC.

Released on 03/02/2022

Russian Harmful Foreign Activities Sanctions

1,003. Are transactions where the Central Bank of the Russian Federation, National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation serves solely as the operator of a clearing and settlement system authorized?

Yes.  Please see General License 14 and FAQ 999.

Released on 03/02/2022

Russian Harmful Foreign Activities Sanctions

1,002. Can U.S. persons engage in indirect transactions with persons subject to Directive 4 under Executive Order (E.O.) 14024, “Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation” (Russia-related Sovereign Transactions Directive)?

No.  The Russia-related Sovereign Transactions Directive prohibits U.S. persons from engaging in any transaction involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation, including any transfer of assets to such entities or any foreign exchange transaction for or on behalf of such entities.  Effective February 28, 2022, U.S. persons may not engage in any transactions involving these entities unless exempt or authorized by the Office of Foreign Assets Control (OFAC).  This includes both direct and indirect transactions.  The Russia-related Sovereign Transactions Directive also prohibits:  (1) any transaction that evades or avoids, has the purpose of evading or avoiding, causes a violation of, or attempts to violate any of the prohibitions of the Russia-related Sovereign Transactions Directive; and (2) any conspiracy formed to violate any of the prohibitions of the Russia-related Sovereign Transactions Directive.  

In light of the current economic situation in Russia, U.S. persons should be on alert for nonroutine foreign exchange transactions that may indirectly involve entities subject to the Russia-related Sovereign Transactions Directive, including transactions that are inconsistent with activity over the 12 months prior to February 28, 2022.  For example, the Central Bank of the Russian Federation may seek to use import or export companies to engage in foreign exchange transactions on its behalf and obfuscate its involvement.  U.S. persons should also exercise caution in engaging in foreign exchange transactions on the Moscow Exchange given the current heightened risk that the Central Bank of the Russia Federation could be a counterparty to such transactions. 

Released on 03/02/2022

Russian Harmful Foreign Activities Sanctions

1,001. Does the 50 Percent Rule apply to Directive 4 under Executive Order (E.O.) 14024, “Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation” (Russia-related Sovereign Transactions Directive)?

No.

Released on 03/02/2022

Russian Harmful Foreign Activities Sanctions

1,000. What sanctions are applicable 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 Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation are subject to several restrictions under the following directives:

• Effective February 28, 2022, Directive 4 under Executive Order (E.O.) 14024, “Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation” (Russia-related Sovereign Transactions Directive), prohibits U.S. persons from engaging in any transaction involving these entities, including any transfer of assets to such entities or any foreign exchange transaction for or on behalf of such entities (see FAQ 998).
• Pursuant to Directive 1A under E.O. 14024, “Prohibitions Related to Certain Sovereign Debt of the Russian Federation” (Russia-related Sovereign Debt Directive), the following activities by a U.S. financial institution are prohibited:
  • As of June 14, 2021, participation in the primary market for ruble or non-ruble denominated bonds issued after June 14, 2021 by the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation; 
  • As of June 14, 2021, lending 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; and
  • As of March 1, 2022, participation in the secondary market for ruble or non-ruble denominated bonds issued after March 1, 2022 by the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation (see FAQ 888).
• Effective August 19, 2019, the Russia-Related Directive (the “CBW Act Directive”) prohibits U.S. banks from participating in the primary market for non-ruble denominated bonds issued by the Russian sovereign and also prohibits U.S. banks from lending non-ruble denominated funds to the Russian sovereign.  The CBW Act Directive defines the term “Russian sovereign” as any ministry, agency, or sovereign fund of the Russian Federation, including the Central Bank of the Russian Federation, the National Wealth Fund, and the Ministry of Finance of the Russian Federation (see FAQs 675 and 676).   

The Russia-related Sovereign Transactions Directive includes prohibitions more expansive than the Russia-related Sovereign Debt Directive and the CBW Act Directive; however, it is important to note that each directive operates independently of the others and may have different effective dates.  Transactions involving these entities must comply with all three directives described above
 

Released on 03/02/2022

Russian Harmful Foreign Activities Sanctions

999. What authorizations exist for entities subject to Directive 4 under Executive Order (E.O.) 14024, “Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation” (Russia-related Sovereign Transactions Directive)?

OFAC issued Russia-related General License (GL) 8A to authorize certain energy-related transactions involving the Central Bank of the Russian Federation that would be prohibited by the Russia-related Sovereign Transactions Directive (see FAQs 976 and 977). 

OFAC issued GL 13 to authorize U.S. persons to pay taxes, fees, or import duties and purchase or receive permits, licenses, registrations, or certifications, to the extent such transactions are prohibited by the Russia-related Sovereign Transactions Directive, provided such transactions are ordinarily incident and necessary to such persons’ day-to-day operations in the Russian Federation.  GLs 8A and 13 expire at 12:01am eastern daylight time, June 24, 2022.

In addition, OFAC issued GLs 9A and 10A.  GL 9A authorizes all transactions prohibited by the Russia-related Sovereign Transactions Directive that are ordinarily incident and necessary to the receipt of interest, dividend, or maturity payments in connection with debt or equity of the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation (collectively, “Directive 4 entities”).  GL 10A authorizes all transactions prohibited by the Russia-related Sovereign Transactions Directive that are ordinarily incident and necessary to the wind down of derivative contracts, repurchase agreements, or reverse repurchase agreements entered into prior to 12:01 a.m. eastern standard time, March 1, 2022, that include a Directive 4 entity as a counterparty.  Note that neither GL 9A nor GL 10A authorizes any debit to an account on the books of a U.S. financial institution of a Directive 4 entity.  In addition, the prior authorizations of GLs 9 and 10 remain unchanged.  GLs 9A and 10A expire at 12:01 a.m. eastern daylight time, May 25, 2022.

OFAC also issued GL 14 authorizing certain transactions involving any Directive 4 entity where the Directive 4 entity’s sole function in the transaction is to act as an operator of a clearing and settlement system.  GL 14 does not authorize any transfer of assets to or from any Directive 4 entity, or any transaction where a Directive 4 entity is either a counterparty or beneficiary to the transaction.  In addition, GL 14 does not authorize any debit to an account on the books of a U.S. financial institution of any Directive 4 entity.  (See FAQ 1003)

Released on 03/02/2022

Russian Harmful Foreign Activities Sanctions

998. What does Directive 4 under Executive Order (E.O.) 14024, “Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation” (Russia-related Sovereign Transactions Directive) do?

The Russia-related Sovereign Transactions Directive prohibits U.S. persons from engaging in any transaction involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation (collectively, “Directive 4 entities”), including any transfer of assets to such entities or any foreign exchange transaction for or on behalf of such entities.  Effective February 28, 2022, U.S. persons may not engage in any transactions involving these entities unless exempt or authorized by the Office of Foreign Assets Control (OFAC).  This includes both direct and indirect transactions involving any Directive 4 entity.  Prohibited transactions include trade or financial transactions and other dealings in which U.S. persons may not engage unless exempt or expressly authorized by OFAC.

The Russia-related Sovereign Transactions Directive also prohibits:  (1)  any transaction that evades or avoids, has the purpose of evading or avoiding, causes a violation of, or attempts to violate any of the prohibitions of the Russia-related Sovereign Transactions Directive; and (2) any conspiracy formed to violate any of the prohibitions of the Russia-related Sovereign Transactions Directive.

This action effectively immobilizes any assets of the Directive 4 entities that are held in the United States or by U.S. persons, wherever located, unless exempt or authorized by OFAC.  Effective February 28, 2022, U.S. financial institutions must reject transactions involving any Directive 4 entity, unless exempt or authorized by OFAC.  OFAC issued general licenses that authorize certain limited transactions involving the Directive 4 entities (see FAQ 999).

Entities determined to be subject to the Russia-related Sovereign Transactions Directive are listed on OFAC’s Non-SDN Menu-Based Sanctions (NS-MBS) List.

Released on 03/02/2022

Russian Harmful Foreign Activities Sanctions

982. Are U.S. funds allowed to buy or sell debt or equity of blocked Russian financial institutions?  Are U.S. investors allowed to invest in a fund that holds debt or equity of a blocked Russian financial institution?

Except as authorized under General License (GL) 9A (see FAQ 981), U.S. persons may not buy or sell debt or equity of the Russian financial institutions blocked in February 2022 pursuant to Executive Order (E.O.) 14024.  Accordingly, a U.S. fund may not buy, sell, or otherwise engage in transactions related to debt or equity of the blocked Russian financial institutions and must block such holdings, unless exempt, authorized under GL 9A or separately authorized by the Office of Foreign Assets Control (OFAC).  However, a U.S. fund that contains such blocked holdings generally is not itself considered a blocked entity as long as the blocked holdings represent less than a predominant share by value of debt or equity of blocked persons.  As a result, U.S. persons may continue to invest in the fund and the fund may continue to operate.  The fund may divest itself of blocked holdings as authorized under GL 9A or separately authorized by OFAC.

Date Updated: March 02, 2022

Updated on 03/02/2022

Russian Harmful Foreign Activities Sanctions

981. What does General License (GL) 9A authorize with respect to the debt and equity of certain Russian financial institutions sanctioned pursuant to Executive Order (E.O.) 14024?  What are the implications for U.S. and non-U.S. persons? 

General License (GL) 9A authorizes U.S. persons, until 12:01 a.m. eastern daylight time May 25, 2022, to engage in transactions prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587, that are ordinarily incident and necessary to dealings in debt or equity issued prior to February 24, 2022 of one or more of the following entities (“covered debt or equity”), provided that any divestment or transfer of, or facilitation of divestment or transfer of, covered debt or equity must be to a non-U.S. person:

• State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank (VEB);
• Public Joint Stock Company Bank Financial Corporation Otkritie; 
• Sovcombank Open Joint Stock Company;
• Public Joint Stock Company Sberbank of Russia;
• VTB Bank Public Joint Stock Company;
• Any entity owned 50 percent or more, directly or indirectly, individually or in the aggregate, by one of the above entities.

This authorization includes the facilitation, clearing, and settling of transactions ordinarily incident and necessary to divest covered debt or equity to a non-U.S. person, including on behalf of U.S. persons.  Also, as part of a divestment transaction to a non-U.S. person, U.S. persons may engage in purchases of or investment in covered debt or equity if ordinarily incident and necessary to buy to cover a short position in such holdings.

To allow the closing of trades initiated before February 24, 2022, paragraph (b) of GL 9A authorizes all transactions that are ordinarily incident and necessary to facilitating, clearing, and settling trades of covered debt or equity through 12:01 a.m. eastern daylight time May 25, 2022, provided such trades were placed prior to 4:00 p.m. eastern standard time on February 24, 2022, including debits to accounts on the books of U.S. financial institutions of certain blocked entities.  

GL 9A also authorizes U.S. persons to receive interest, dividend, or maturity payments on debt or equity of the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation through 12:01 a.m. eastern daylight time on May 25, 2022.  After May 25, 2022, U.S. persons would require a specific license to continue to receive such payments.  

Certain transactions otherwise prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587, are not authorized by GL 9A.  Please see GL 9A for additional details.  Please also see GL 10A with respect to authorizations related to certain derivative contracts. 

For purposes of assessing whether certain transactions are authorized under GL 9A or GL 10A, U.S. persons—including financial institutions, registered broker-dealers in securities, securities exchanges, and other market intermediaries and participants—may rely upon the information available to them in the ordinary course of business, including reasonable reliance on information about the underlying transaction provided by the parties thereto.  However, U.S. persons should also exercise caution in engaging in foreign exchange transactions on the Moscow Exchange given the current heightened risk that the Central Bank of the Russia Federation could be a counterparty to such transactions (see FAQ 1002). 

Date Updated: March 02, 2022

Updated on 03/02/2022

Russian Harmful Foreign Activities Sanctions

978. For transactions authorized under Russia-related General Licenses (GL) 6, 7, or 8A what is an example of a permissible funds transfer involving a foreign financial institution sanctioned pursuant to Executive Order (E.O.) 14024? 

GLs 6, 7, and 8A do not authorize a U.S. financial institution to maintain (or open) a correspondent account or payable-through account for or on behalf of entities subject to the prohibitions of Directive 2 under E.O.  14024 , “Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions” (Russia-related CAPTA Directive).  Consequently, in order for a U.S. financial institution to engage in transactions authorized under these GLs (e.g., a funds transfer related to energy), all such funds transfers must be processed indirectly through a non-sanctioned, non-U.S. financial institution.  

Examples of authorized and prohibited funds transfers under GLs 6, 7, and 8A include:

Payment from third-country originator

Authorized payment from third-country originator to beneficiary with an account at a sanctioned institution:

Prohibited payment from third-country originator to beneficiary with an account at a sanctioned institution: 

 

Payment from U.S. originator

Authorized payment from U.S. originator to beneficiary with an account at a sanctioned institution:

Prohibited payment from U.S. originator to beneficiary with an account at a sanctioned institution: 

In each of the above examples, the underlying funds transfer must be authorized under the applicable GL.
 

Date Updated: March 02, 2022

Updated on 03/02/2022

Russian Harmful Foreign Activities Sanctions

977. What are transactions “related to energy” for purposes of Russia-related General License (GL) 8A? 

For the purposes of GL 8A,  the term “related to energy” means the extraction, production, refinement, liquefaction, gasification, regasification, conversion, enrichment, fabrication, transport, or purchase of petroleum, including crude oil, lease condensates, unfinished oils, natural gas liquids, petroleum products, natural gas, or other products capable of producing energy, such as coal, wood, or agricultural products used to manufacture biofuels, or uranium in any form, as well as the development, production, generation, transmission, or exchange of power, through any means, including nuclear, thermal, and renewable energy sources. This definition remains unchanged from GL 8.

Date Updated: March 02, 2022

Updated on 03/02/2022

Russian Harmful Foreign Activities Sanctions

976. Can a U.S. financial institution process transactions related to energy where a Russian financial institution sanctioned pursuant to Executive Order (E.O.) 14024 is involved?  

General License (GL) 8A  authorizes certain transactions “related to energy” (as defined in the GL; see also FAQ 977) involving the following entities (collectively, “Covered Entities”):

•    State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank (VEB);
•    Public Joint Stock Company Bank Financial Corporation Otkritie;
•    Sovcombank Open Joint Stock Company;
•    Public Joint Stock Company Sberbank of Russia;
•    VTB Bank Public Joint Stock Company; 
•    Any entity owned 50 percent or more, directly or indirectly, individually or in the aggregate, by one of the above entities; and
•    The Central Bank of the Russian Federation.

GL 8A does not authorize any transaction prohibited by Directive 1A under E.O. 14024, “Prohibitions Related to Certain Sovereign Debt of the Russian Federation” (Russia-related Sovereign Debt Directive).  In addition, GL 8A does not authorize any debit to an account on the books of a U.S. financial institution of the Central Bank of the Russian Federation.  Further, GL 8A does not authorize a U.S. financial institution to maintain (or open) a correspondent account or payable-through account for or on behalf of foreign financial institutions subject to the prohibitions of the Russia-related CAPTA Directive.  Consequently, in order for a U.S. financial institution to engage in transactions authorized by GL 8A, all funds transfers related to energy involving one or more Covered Entities must be processed indirectly through a non-sanctioned, non-U.S. financial institution.  Please see FAQ 978 for examples of authorized and prohibited transactions flows under certain GLs, including GL 8A.

For purposes of assessing whether certain transactions are authorized under GL 8A, U.S. persons may rely upon the information available to them in the ordinary course of business, including reasonable reliance on information about the underlying transaction provided by the parties thereto.  

GL 8A is valid until 12:01 eastern daylight time, June 24, 2022 unless renewed.  Persons unable to wind down prohibited transactions with the Covered Entities by June 24, 2022 are encouraged to approach OFAC, which may consider renewing GL 8A.

Date Updated: March 02, 2022

Updated on 03/02/2022

Russian Harmful Foreign Activities Sanctions

974. What Russian financial institutions were blocked in February 2022 pursuant to Executive Order (E.O.) 14024, and what activities are prohibited as a result?

On February 22, 2022, the Office of Foreign Assets Control (OFAC) designated specified Russian financial institutions pursuant to E.O. 14024 , including the State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank (VEB), Promsvyazbank Public Joint Stock Company, and many of their subsidiaries.  OFAC designated additional Russian financial institutions on February 24, 2022, including VTB Bank Public Joint Stock Company, Public Joint Stock Company Bank Financial Corporation Otkritie (Otkritie), Sovcombank Open Joint Stock Company (Sovcombank), Joint Stock Commercial Bank Novikombank, and many of these financial institutions’ subsidiaries.  As a result, all property and interests in property of these entities in the possession or control of U.S. persons, including U.S. financial institutions, or within U.S. jurisdiction, are blocked and must be reported to OFAC.  In addition, all property and interests in property of any entity that is owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked.  Accordingly, U.S. persons, including U.S. financial institutions, are prohibited from transacting with these entities unless exempt or authorized by OFAC.  

OFAC issued several Russia-related general licenses (GLs) authorizing transactions involving specified blocked Russian financial institutions, including:
•    GL 2 : authorizing certain transactions involving VEB related to servicing obligations of certain Russian sovereign debt; 
•    GL  3: authorizing the wind down of certain transactions involving VEB until 12:01 a.m. eastern daylight time, March 24, 2022;
•    GL  11: authorizing the wind down of certain transactions involving VTB Bank Public Joint Stock Company, Otkritie, and Sovcombank until 12:01 a.m. eastern daylight time, March 24, 2022; and
•    GL  12: authorizing the rejection (rather than blocking) of certain transactions involving VTB Bank Public Joint Stock Company, Otkritie, and Sovcombank until 12:01 a.m. eastern daylight time, March 24, 2022.

Note that these GLs do not authorize certain activities with all blocked Russian financial institutions; nor does each GL authorize certain activities with the same group of blocked Russian financial institutions.  For example, the GLs listed above do not authorize any transactions involving Promsvyazbank Public Joint Stock Company or Joint Stock Commercial Bank Novikombank, and GLs 2 and 3  relate only to VEB.  

Other GLs  that may be applicable to one or more of the Russian financial institutions blocked in February 2022 include:

•    GL  5: authorizing transactions related to the official business of certain international organizations and other entities; 
•    GL  6: authorizing certain transactions related to the exportation or reexportation of agricultural commodities, medicine, medical devices, replacement parts and components, or software updates, or the prevention, diagnosis, or treatment of COVID-19; 
•    GL  7: authorizing overflight payments, emergency landings, and air ambulance services;

•    GL  8A: authorizing transactions related to energy; 
•    GL  9A: authorizing transactions related to dealings in certain debt and equity until 12:01 a.m. eastern daylight time, May 25, 2022; and
•    GL  10A: authorizing certain transactions related to derivative contracts until 12:01 a.m. eastern daylight time, May 25, 2022. 

Please consult each GL for further information regarding its scope.  

On March 1, 2022, OFAC issued the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR), which incorporate GL 5 in section 587.510 of the RuHSR.

Additionally, consistent with section 9 of E.O. 14024, transactions for the conduct of the official business of the Federal Government or the United Nations (including its specialized agencies, programs, funds, and related organizations) by employees, grantees, and contractors thereof are exempt from the sanctions prohibitions of E.O. 14024.

Date Updated: March 02, 2022

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967. What does 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) prohibit?

The Russia-related CAPTA Directive prohibits U.S. financial institutions from:  (i) the opening or maintaining of a correspondent account or payable-through account for or on behalf of foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive; and (ii) the processing of transactions involving foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive.  Please see the Russia-related CAPTA Directive for the definition of the terms “U.S. financial institution” and “foreign financial institution” for purposes of this directive.  Please see FAQ 969 regarding the applicability of OFAC’s 50 Percent Rule with respect to this directive.

Annex 1 to the Russia-related CAPTA Directive lists the foreign financial institutions determined to be subject to the prohibitions as of March 26, 2022.  Foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive, including the foreign financial institutions listed in Annex 1, can be found on the Office of Foreign Assets Control’s (OFAC) List of Foreign Financial Institutions Subject to Correspondent Account or Payable-Through Account Sanctions (CAPTA List).  Relevant entries on the CAPTA List will denote when a foreign financial institution became subject to the prohibitions of the Russia-related CAPTA Directive, as well as when the prohibitions of the Russia-related CAPTA Directive come into effect with respect to that foreign financial institution.

The below table identifies the dates the prohibitions of the Russia-related CAPTA Directive take effect for (i) foreign financial institutions listed in Annex 1 to the Russia-related CAPTA Directive, and (ii) foreign financial institutions otherwise determined to be subject to its prohibitions and added to the CAPTA List.

Foreign Financial Institution Type

Foreign financial institutions listed in Annex 1 to the Russia-related CAPTA Directive

Relevant Sanctions Effective Date

12:01 a.m. eastern daylight time on March 26, 2022

Foreign Financial Institution Type

Foreign financial institution otherwise determined to be subject to the prohibitions of the Russia-related CAPTA Directive

Relevant Sanctions Effective Date

12:01 a.m. eastern time on the date that is 30 days after the date of such determination

U.S. financial institutions must close any correspondent or payable-through account maintained for or on behalf of foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive, or their property or interests in property, by the relevant effective date.  Separately, as of the relevant effective date, U.S. financial institutions may not process transactions involving foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive, or their property or interests in property, and must reject such transactions unless exempt or authorized by OFAC.

Accordingly, after the relevant effective date, U.S. financial institutions must reject any transaction involving a foreign financial institution determined to be subject to the prohibitions of the Russia-related CAPTA Directive or involving that foreign financial institution’s property or interests in property.  This includes rejecting transactions related to any securities (including depositary receipts) issued by a foreign financial institution determined to be subject to the prohibitions of the Russia-related CAPTA Directive, including secondary market trading. For certain authorized securities-related transactions, see GL 9A and FAQ 981.  By virtue of the prohibition on the processing of transactions for or on behalf of foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive, U.S. financial institutions are also prohibited from engaging in transactions with a covered foreign financial institution in connection with the foreign financial institution’s role as a local custodian for depositary receipt issuances.

The Russia-related CAPTA Directive does not impose blocking sanctions and, thus, does not require U.S. financial institutions (or other U.S. persons) to block the assets of foreign financial institutions determined to be subject to the prohibitions of this directive.  However, U.S. persons should be aware that foreign financial institutions subject to the prohibitions of the Russia-related CAPTA Directive may also be subject to additional prohibitions under other sanctions authorities, such as additional directives under E.O. 14024  or E.O. 13662.

OFAC issued several Russia-related general licenses (GLs) authorizing certain transactions involving the foreign financial institutions subject to the prohibitions of the Russia-related CAPTA Directive, including:

• GL 5: authorizing transactions related to the official business of certain international organizations and other entities; 
• GL 6: authorizing transactions related to the exportation or reexportation of agricultural commodities, medicine, medical devices, replacement parts and components, or software updates, or the prevention, diagnosis, or treatment of COVID-19; 
• GL 7: authorizing overflight payments, emergency landings, and air ambulance services;
• GL 8A: authorizing transactions related to energy; 
• GL 9A: authorizing transactions related to dealings in certain debt and equity until 12:01 a.m. eastern daylight time, May 25, 2022; and
• GL 10A: authorizing certain transactions related to derivative contracts until 12:01 a.m. eastern daylight time, May 25, 2022.  
   

On March 1, 2022, OFAC issued the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR), which incorporate GL 5 in section 587.510 of the RuHSR.

For additional information, please see FAQs 976, 977, 978, 979, 981, 982 and 990.

Date Updated: March 02, 2022

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966. What actions did Treasury take in February 2022 related to Russia’s financial services sector pursuant to Executive Order (E.O.) 14024?

Treasury took expansive sanctions actions related to Russia’s financial services sector in February 2022 as detailed below.

• Financial services sector determination.  On February 22, 2022, the Secretary of the Treasury, in consultation with the Secretary of State, issued a determination pursuant to E.O. 14024 that authorizes sanctions against persons determined to operate or to have operated in the financial services sector of the Russian Federation economy (see FAQ 964).  
• Correspondent or payable-through account and payment processing prohibitions.  On February 24, 2022, the Office of Foreign Assets Control (OFAC) issued Directive 2 under E.O. 14024, “Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions” (Russia-related CAPTA Directive), which prohibits U.S. financial institutions from:  (i) the opening or maintaining of a correspondent account or payable-through account for or on behalf of foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive; and (ii) the processing of transactions involving foreign financial institutions determined to be subject to the prohibitions of the Russia-related CAPTA Directive.  Annex 1 to the Russia-related CAPTA Directive identifies Public Joint Stock Company Sberbank of Russia and other foreign financial institutions owned 50 percent or more by this bank as subject to these prohibitions, which become effective on March 26, 2022 (see FAQs 964, 967, 968, 969, 970, 971, 972 and 973).
• Blocking certain Russian financial institutions.  OFAC designated specified Russian financial institutions pursuant to E.O. 14024, including the State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank (VEB), VTB Bank Public Joint Stock Company, Public Joint Stock Company Bank Financial Corporation Otkritie, Promsvyazbank Public Joint Stock Company, Sovcombank Open Joint Stock Company, Joint Stock Commercial Bank Novikombank, and several of these financial institutions’ subsidiaries.  As a result, all property and interests in property of these entities in the possession or control of U.S. persons, including U.S. financial institutions, or within U.S. jurisdiction, are blocked and must be reported to OFAC.  In addition, all property and interests in property of any entity that is owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked.  Accordingly, U.S. persons, including U.S. financial institutions, are prohibited from transacting with these entities unless exempt or authorized by OFAC (see FAQs 974, 975, 976, 977, 978, 979, 980, 981, and 982).  
• Expanding sovereign debt prohibitions to include the secondary market.  On February 22, 2022, OFAC issued Directive 1A under E.O. 14024, “Prohibitions Related to Certain Sovereign Debt of the Russian Federation” (Russia-related Sovereign Debt Directive), replacing and superseding Directive 1 under E.O. 14024 of April 15, 2021, to extend existing sovereign debt prohibitions to cover participation in the secondary market for ruble or non-ruble denominated bonds issued after March 1, 2022 by the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation (see FAQs 888, 889, 890, 891, 965, and 983).  
• New debt and equity restrictions involving certain Russia-related entities.  On February 24, 2022, OFAC imposed additional debt and equity restrictions involving Russia-related entities by issuing Directive 3 under E.O. 14024, “Prohibitions Related to New Debt and Equity of Certain Russia-related Entities” (Russia-related Entities Directive), to prohibit certain dealings by U.S. persons, or within the United States, in new debt of longer than 14 days maturity or new equity of Russia-related entities determined to be subject to the prohibitions of the Russia-related Entities Directive.  OFAC determined on February 24, 2022 that the entities listed in Annex 1 to the Russia-related Entities Directive, which include certain major Russian state-owned enterprises and large privately owned financial institutions, are subject to the prohibitions of this directive for new debt or equity issued on or after March 26, 2022 (see 983, 984, 985, 986, 987, 988 and 989). 
• General Licenses (GLs).  OFAC issued several Russia-related GLs authorizing certain transactions otherwise prohibited by E.O. 14024 (see FAQs 974, 975, 976, 977, 978, 979, 981, 982, and 990).
• New restrictions on sovereign transactions.  On February 28, 2022, OFAC issued Directive 4 under E.O. 14024, “Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation” (Russia-related Sovereign Transactions Directive) to prohibit U.S. persons from engaging in any transaction involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation, including any transfer of assets to such entities or any foreign exchange transaction for or on behalf of such entities (see FAQs 998 – 1003).

Date Updated: March 02, 2022

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965. 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?

Directive 1 under E.O. 14024 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 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 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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919. How do sanctions related to U.S. bank loans imposed on Russia pursuant to the Chemical and Biological Weapons Control and Warfare Act of 1991 (CBW Act), as announced by the State Department on August 20, 2021, affect existing prohibitions?

The prohibitions announced by the State Department on August 20, 2021 related to U.S. bank loans have the same scope as those imposed by OFAC in August 2019 under the CBW Act Directive.  Please see FAQs 675–678 for additional information.

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 (see FAQ 1000).

Date Updated: March 02, 2022

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890. Prior to June 14, 2021, are U.S. financial institutions prohibited from participating in the primary market for ruble or non-ruble denominated bonds issued by, or lending 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?

Even prior to June 14, 2021, “U.S. banks” were prohibited from participating in the primary market for non-ruble denominated bonds issued by the Russian sovereign (including the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation), and from lending non-ruble denominated funds to the Russian sovereign pursuant to the Russia-related Directive under Executive Order 13883 (“CBW Act Directive”), which was issued on August 2, 2019 and went into effect on August 26, 2019.  However, the CBW Act Directive does not prohibit “U.S. banks” (as defined in the CBW Act Directive) from participating in the primary market for ruble denominated bonds issued by the Russian sovereign, or the lending of ruble denominated funds to the Russian sovereign.

Pursuant to Directive 1A under (E.O.) 14024 , “Prohibitions Related to Certain Sovereign Debt of the Russian Federation” (Russia-related Sovereign Debt Directive), after June 14, 2021, U.S. financial institutions (as defined in the Russia-related Sovereign Debt Directive) are prohibited from participating 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, unless otherwise authorized by OFAC or exempt.  Pursuant to the Russia-related Sovereign Debt Directive, as of March 1, 2022, U.S. financial institutions are also prohibited from participating in the secondary market for ruble or non-ruble denominated bonds issued after March 1, 2022 by these entities. 

Note that the prohibitions found in the CBW Act Directive remain in effect and are separate from the prohibitions of the Russia-related Sovereign Debt Directive, or other directives under E.O. 14024.  For more information on the CBW Act Directive, please see FAQs 673 – 678.

Date Updated: March 02, 2022

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888. What does Directive 1A under Executive Order (E.O.) 14024, “Prohibitions Related to Certain Sovereign Debt of the Russian Federation” (Russia-related Sovereign Debt Directive) do?

Pursuant to the Russia-related Sovereign Debt Directive, the following activities by a U.S. financial institution are prohibited:

1. As of June 14, 2021, participation in the primary market for ruble or non-ruble denominated bonds issued after June 14, 2021 by the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation; 
2. As of June 14, 2021, lending 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; and
3. As of March 1, 2022, participation in the secondary market for ruble or non-ruble denominated bonds issued after March 1, 2022 by the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation.

Further, except to the extent otherwise provided by law or unless authorized by OFAC or exempt, the following are also prohibited pursuant to the Russia-related Sovereign Debt Directive:  (1) any transaction that evades or avoids, has the purpose of evading or avoiding, causes a violation of, or attempts to violate any of the prohibitions of the Russia-related Sovereign Debt Directive; and (2) any conspiracy formed to violate any of the prohibitions of the Russia-related Sovereign Debt Directive. 

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 Executive Order (E.O.) 13883 and E.O. 14024.

Date Updated: March 02, 2022

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

No, the CBW Act Directive 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 (see FAQ 1000).

Date Updated: March 02, 2022

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676. What do the CBW Act Directive terms “U.S. bank” and “Russian sovereign” mean?

The CBW Act Directive defines the term “U.S. banks.”  This definition is consistent with section 4(c) of Executive Order (E.O.) 13883, and with the definition of “U.S. financial institution” at 31 CFR § 544.311.  The CBW Act Directive defines the term “Russian sovereign” as any ministry, agency, or sovereign fund of the Russian Federation, including the Central Bank of the Russian Federation, the National Wealth Fund, and the Ministry of Finance of the Russian Federation.   This term does not include state-owned enterprises of the Russian Federation.

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 E.O. 14024 (see FAQ 1000).

Date Updated: March 02, 2022

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675. How does OFAC implement sanctions related to U.S. bank loans imposed on Russia pursuant to the CBW Act?

Pursuant to Executive Order (E.O.). 13883, 31 CFR § 544.802, and the CBW Act, on August 2, 2019, OFAC issued a Russia-Related Directive (the “CBW Act Directive”), which prohibits U.S. banks from participating in the primary market for non-ruble denominated bonds issued by the Russian sovereign and also prohibits U.S. banks from lending non-ruble denominated funds to the Russian sovereign.  The prohibitions under the CBW Act Directive do not apply to bonds or loans denominated in rubles.  The prohibitions in the CBW Act Directive only apply to “U.S. banks,” as that term is defined in the CBW Act Directive and consistent with section 4(c) of E.O. 13883 and consistent with the definition of U.S. financial institution at 31 CFR § 544.311.  The CBW Act Directive includes a definition of the term “Russian sovereign.”  The CBW Act Directive is effective as of August 26, 2019.

Independent of the CBW Act Directive, OFAC has imposed additional prohibitions on certain Russia-related sovereign entities subject to the CBW Act Directive, pursuant to Russia-related directives under E.O. 14024 (see FAQ 1000).

Date Updated: March 02, 2022

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