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OFFICE OF FOREIGN ASSETS CONTROL
DIRECTIVE 3 UNDER EXECUTIVE ORDER 14024
Prohibitions Related to New Debt and Equity of Certain Russia-related Entities
Pursuant to sections 1(a), 1(d), and 8 of Executive Order 14024, “Blocking Property With Respect To Specified Harmful Foreign Activities of the Government of the Russian Federation” (the “Order”), the Director of the Office of Foreign Assets Control, in consultation with the Department of State, has determined that the following activities by U.S. persons or within the United States are prohibited, except to the extent provided by law, or unless licensed or otherwise authorized by the Office of Foreign Assets Control:
(1) For new debt or new equity of entities listed in Annex 1, or their property or interests in property, all transactions in, provision of financing for, and other dealings in new debt of longer...
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1) Directive 3 under EO 14024 appears to impose prohibitions identical in scope to the debt/equity related prohibition in the Ukraine-related SSI Directives (SSI Directive 1, SSI Directive 2 and SSI Directive 3. See the following FAQs, addressing Directive 3 in particular: FAQ # 675, FAQ # 676, FAQ # 966, FAQ # 980, FAQ # 983, FAQ # 984, FAQ # 985, FAQ # 986, FAQ # 987, FAQ # 988, FAQ # 989.
2) See generally General Note on the Prohibitions on Dealings in “New Debt” of Certain Sanctions Targets (System Ed. Note).
3) Note that JOINT STOCK COMPANY SOVCOMFLOT, an SDN as of 23 Feb....