Directive 3 - Prohibitions Related to New Debt and Equity of Certain Russia-related Entities (February 24, 2022)

Date issued: Feb. 24 2022

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TURBOFAC Commentary (137 words)

Notes:

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....