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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

Date Released
April 15, 2021