Frequently Asked Questions

Yes.  The prohibitions of the Russia-related CAPTA Directive apply to a U.S. financial institution’s opening or maintaining of a correspondent account or payable-through account for or on behalf of, or processing of a transaction involving, any FFI, wherever located outside of the United States,… Read more

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 institution… Read more

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

On February 22, 2022, the Office of Foreign Assets Control (OFAC) designated specified Russian financial institutions pursuant to E.O. 14024 , including the State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank (VEB), Promsvyazbank Public Joint Stock Company, and many… Read more

For certain Russian financial institutions blocked in February 2022 pursuant to E.O. 14024 , a short-term wind-down period is authorized.   General License (GL) 3 authorizes a wind-down period of 30 days for transactions involving State Corporation Bank for Development and Foreign Economic Affairs… Read more

On January 10, 2025, OFAC issued amended GL 8L to authorize the wind-down of transactions related to energy involving certain Russian financial institutions sanctioned pursuant to E.O. 14024 through 12:01 a.m. eastern daylight time, March 12, 2025. For the purposes of GL 8L , the term "related to… Read more

Yes, U.S. persons supporting activities undertaken for the official business of certain international organizations or entities, certain humanitarian-related trade, or the response to the COVID-19 pandemic may continue to engage in such activity involving persons sanctioned pursuant to E.O. 14024… Read more

OFAC evaluates a range of factors when developing sanctions targets, consistent with foreign policy and national security goals.  In the context of blocking sanctions, non-U.S. persons may be exposed to sanctions risk in relation to activities with persons subject to blocking sanctions pursuant to… Read more

General License (GL) 9A  authorizes U.S. persons, until 12:01 a.m. eastern daylight time May 25, 2022, to engage in transactions prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587, that are ordinarily incident and necessary to dealings in debt or equity… Read more

Unless otherwise authorized, U.S. persons may not buy or sell debt or equity of the Russian financial institutions blocked pursuant to Executive Order (E.O.) 14024 .  Accordingly, a U.S. fund may not buy, sell, or otherwise engage in transactions related to debt or equity of such blocked Russian… Read more