Frequently Asked Questions

675 … Pursuant to Executive Order (E.O.). 13883 , 31 CFR § 544.802, and the CBW Act, on August 2, 2019, OFAC issued a Russia-Related Directive (the “CBW Act Directive”) , which prohibits U.S. banks from participating in the primary market for non-ruble denominated bonds issued by the Russian… Read more

676 … 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,… Read more

677 … The CBW Act Directive imposes long-term costs on Russia for its brazen use of chemical weapons and its failure to meet the conditions described in the CBW Act, including the failure to provide reliable assurances that Russia would not engage in future chemical weapons attacks. The Government… Read more

678 … No, the CBW Act Directive does not prohibit U.S. banks from participating in the secondary market for Russian sovereign debt.  However, independent of the CBW Act Directive, OFAC has imposed prohibitions on certain Russia-related sovereign entities subject to the CBW Act Directive, pursuant… Read more