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986. What constitutes debt or equity for purposes of Directive 3 under Executive Order (E.O.) 14024, “Prohibitions Related to New Debt and Equity of Certain Russia-related Entities” (Russia-related Entities Directive)?
The term “debt” includes bonds, loans, extensions of credit, loan guarantees, letters of credit, drafts, bankers acceptances, discount notes or bills, or commercial paper.
The term “equity” includes stocks, share issuances, depositary receipts, or any other evidence of title or ownership.
Date Released
February 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)