Frequently Asked Questions

888. What does Directive 1A under Executive Order (E.O.) 14024, “Prohibitions Related to Certain Sovereign Debt of the Russian Federation” (Russia-related Sovereign Debt Directive) do?

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. What does Executive Order (E.O.) 14024, “Blocking Property with Respect to Specified Harmful Foreign Activities of the Government of the Russian Federation” do?

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. Are persons identified pursuant to Executive Order (E.O.) 13662 as subject to Directive 3 for operating in the defense and related materiel sector of the Russian Federation economy blocked pursuant to E.O. 14024?

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. 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 issued by the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation?

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. Prior to June 14, 2021, are U.S. financial institutions prohibited from participating in the primary market for ruble or non-ruble denominated bonds issued by, or lending ruble or non-ruble denominated funds 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?

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. Does the 50 Percent Rule apply to Directive 1A under Executive Order (E.O.) 14024, “Prohibitions Related to Certain Sovereign Debt of the Russian Federation” (Russia-related Sovereign Debt Directive)?

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

894. What does Russia-related General License (GL) 1B authorize?

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

987. If a U.S. person entered into a revolving credit facility or long-term loan agreement for an entity determined to be subject to Russia-related Directive 3 under Executive Order (E.O.) 14024, “Prohibitions Related to New Debt and Equity of Certain Russia-related Entities” (Russia-related Entities Directive) prior to the relevant sanctions effective date described in the Russia-related Entities Directive, what are the restrictions on drawdowns from that facility? Do all drawdowns and disbursements pursuant to the parent agreement need to carry repayment terms of 14 days or less?

987 … If a U.S. person entered into a long-term credit facility or loan agreement prior to the relevant sanctions effective date described in the Russia-related Entities Directive, drawdowns and disbursements with repayment terms of 14 days or less are permitted. In addition, drawdowns and… Read more

988. Does Russia-related Directive 3 under Executive Order (E.O.) 14024, “Prohibitions Related to New Debt and Equity of Certain Russia-related Entities” (Russia-related Entities Directive) prohibit U.S. persons from engaging in all activities with entities subject to it?

988 … No. The Russia-related Entities Directive prohibits U.S. persons from engaging in only certain activities related to new debt of longer than 14 days maturity or new equity of the entities listed in Annex 1 to the Russia-related Entities Directive, or of entities otherwise determined to be… Read more

989. Does Russia-related Directive 3 under Executive Order (E.O.) 14024, “Prohibitions Related to New Debt and Equity of Certain Russia-related Entities” (Russia-related Entities Directive) prohibit U.S. persons from engaging in dealings related to debt or equity issued before the relevant sanctions effective date by entities subject to it?

989 … No, so long as the terms of such debt (including the repayment period, the interest rate, and the amount) were contractually agreed to before the relevant sanctions effective date described in the Russia-related Entities Directive and are not modified on or after the relevant sanctions… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence