405. Does the prohibition on “otherwise dealing in new debt” of longer than the applicable tenor specified in the relevant Directive of SSI entities, their property, or their interests in property prohibit dealing in debt with maturity that exceeds the applicable authorized tenor in which the SSI entity is not directly or indirectly the borrower?

Directives 1, 2, and 3 only prohibit U.S. persons from dealing in new debt that is issued by a person subject to the relevant Directive (and only where the debt has a tenor that exceeds the applicable tenor specified in the relevant Directive).  Directives 1, 2, and 3 do not prohibit U.S. persons from dealing with an SSI entity as counterparty to transactions involving debt issued on or after the sanctions effective date by a non-sanctioned party.