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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?
Pursuant to the Russia-related Sovereign Debt Directive, the following activities by a U.S. financial institution are prohibited:
1. 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 Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation;
2. As of June 14, 2021, 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; and
3. As of March 1, 2022, participation in the secondary market for ruble or non-ruble denominated bonds issued after...
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1) See Consolidated Comment on the Russia-related Lending Directives. This FAQ essentially restates the text of Directive 1A Under Executive Order 14024 (amended on 2-22-2022 to account for Directive 1A superseding the initial Directive.
In the amended FAQ, OFAC raises the possibility that transactions otherwise prohibited by the Directive could be "exempt". Standard IEEPA exemptions apply to EO 14024, but the EO also has an "official business" exemption that applies to the USG and the UN and its associated agencies. This exemption may prove significant.
[3-2-22 update - FAQ amended to account for the issuance of Directive 4 Under EO 14024.]