Date issued: Feb. 24 2022
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1) OFAC appears to have adopted a position of interpreting the debt and equity prohibitions of the SSI Directives harmoniously with the prohibitions found in Directive 3 under EO 14024. Compare FAQ # 371 and FAQ # 511, defining the terms in the same way.
* See generally General Note on the Prohibitions on Dealings in “New Debt” of Certain Sanctions Targets (System Ed. Note)