Frequently Asked Questions

921 … The Protecting Europe’s Energy Security Act of 2019, 22 U.S.C. 9526 note, as amended (PEESA), requires the imposition of sanctions with respect to the provision of vessels engaged in specified activities for the construction of certain Russian energy export pipelines, including the Nord… Read more

894 … Russia-related GL 1B authorizes U.S. persons to engage in certain transactions and activities involving the Federal State Budgetary Institution Marine Rescue Service (MRS) that are otherwise prohibited by Executive Order (E.O.) 14039 of August 20, 2021, "Blocking Property with Respect to… Read more

888 … Pursuant to the Russia-related Sovereign Debt Directive , the following activities by a U.S. financial institution are prohibited: As of June 14, 2021, participation in the primary market for ruble or non-ruble denominated bonds issued after June 14, 2021 by the Central Bank of the Russian… Read more

886 … E.O. 14024 establishes a new national emergency under which sanctions may be imposed against individuals and entities furthering specified harmful foreign activities of the Russian Federation.  This national emergency is separate from the national emergency relating to the crisis in Ukraine,… Read more

887 … Persons identified pursuant to E.O. 13662 as subject to Directive 3 for operating in the defense and related materiel sector of the Russian Federation economy are not subject to prohibitions under E.O. 14024 unless those persons are also sanctioned pursuant to E.O. 14024.   For more… Read more

889 … Yes (see FAQ 888 and FAQ 965 ). Date Updated: February 22, 2022 … Does Directive 1A under Executive Order (E.O.) 14024, “Prohibitions Related to Certain Sovereign Debt of the Russian Federation” (Russia-related Sovereign Debt Directive) prohibit participation in the secondary market for bonds… Read more

890 … Even prior to June 14, 2021, “U.S. banks” were prohibited from participating in the primary market for non-ruble denominated bonds issued by the Russian sovereign (including the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of… Read more

891 … No.  The prohibitions of the Russia-related Sovereign Debt Directive  apply only to bonds issued by, or loans made to, the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation.  The prohibitions of the… Read more

971 … No.  The prohibitions of the Russia-related CAPTA Directive apply with respect to any currency.  For example, a foreign branch of a U.S. financial institution may not open or maintain a correspondent account for or on behalf of, or process a transaction involving, a foreign financial… Read more

973 … With respect to foreign financial institutions subject to the prohibitions of Directive 2 under E.O. 14024 , “Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions” ( Russia-related CAPTA Directive ),… Read more