948. Does Directive 1 under E.O. 14038 prohibit U.S. persons from entering into derivatives contracts linked to new debt issued by the Ministry of Finance of the Republic of Belarus or the Development Bank of the Republic of Belarus?

Yes.  Transactions by U.S. persons and within the United States involving derivative products whose value is linked to an underlying asset that constitutes prohibited debt issued by a person subject to Directive 1 under E.O. 14038 are prohibited, unless otherwise authorized by the Office of Foreign Assets Control.