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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?
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 Finance of the Russian Federation), and from lending non-ruble denominated funds to the Russian sovereign pursuant to the Russia-related Directive under Executive Order 13883 (“CBW Act Directive”), which was issued on August 2, 2019 and went into effect on August 26, 2019. However, the CBW...
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1) See section IV of Consolidated Comment on the Russia-related Lending Directives. The U.S. persons subject to the two different directives appear to be same.
This FAQ was amended on 2-22-2022 to account for the issuance of Directive 1A Under Executive Order 14024 . It does not provide much in the way of interpretive guidance.
2) FAQ amended on 2-3-2022 to add (accounting for Directive 4) "Note that the prohibitions found in the CBW Act Directive remain in effect and are separate from the prohibitions of the Russia-related Sovereign Debt Directive, or other directives under E.O. 14024."