No. U.S. persons, including U.S. financial institutions, may transfer securities issued by non-blocked Russian entities from a decedent’s estate to the account of a relevant beneficiary or beneficiaries, including a successor entity (e.g., a family trust), provided such transfers (i) are part of the ordinary course administration of the decedent’s estate, (ii) do not involve an exchange for value, and (iii) have no other sanctions nexus (including the involvement of blocked persons).
Please note, however, that blocked securities in a decedent’s estate must remain blocked. The administration of a decedent’s estate requiring the transfer of blocked securities would require a specific license from OFAC. To apply for a specific license, please go to our License Application Page.