Yes. On June 12, 2024, OFAC designated the National Settlement Depository (NSD), along with the Moscow Exchange (MOEX) and the National Clearing Center (NCC) pursuant to Executive Order (E.O.) 14024 for operating or having operated in the financial services sector of the Russian Federation economy. As noted in the accompanying press release, Russia has reoriented the architecture of its financial system to facilitate investment into its defense industry and acquisition of goods needed to further its aggression against Ukraine.
Alongside this designation, OFAC issued, and subsequently extended, two general licenses (GLs) to allow for the wind down of certain transactions involving NSD, MOEX, and NCC, and the divestment of securities held at NSD, among other authorized activities. Following the expiration of Russia-related GLs 99A and 100A, any securities in the possession or control of U.S. persons that are held at NSD should be treated as blocked, and dividends or other income received via NSD should be treated as blocked.
A version of this FAQ released on October 10, 2024 provided guidance that the Russian Federation has attempted to take action to evade or avoid OFAC sanctions on NSD via Presidential Decree 840 by requiring the transfer of certain securities to local Russian registrars. This FAQ cautioned that such transfers may be considered null and void pursuant to OFAC's regulations (see 31 CFR § 587.202), and that OFAC understands that these transactions may involve other blocked persons, including certain local Russian registrars. This FAQ also noted that the general licenses did not authorize transactions involving any blocked person other than those identified in the authorizations, and that any transfer made in violation of OFAC sanctions is null and void. As such, OFAC cautioned that U.S. persons should continue to treat these securities as blocked.
On November 21, 2024, OFAC designated more than 40 local Russian registrars pursuant to E.O. 14024. As such, any securities in the possession or control of U.S. persons that are held at these registrars should be treated as blocked, and dividends or any income received via these registrars should be treated as blocked. Any U.S. persons who have already filed initial blocking reports on such securities do not need to file amended reports solely due to a change in local Russian registrar and can use their Annual Reports of Blocked Property to reflect any updated information if necessary.
Date Updated: November 21, 2024