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OFFICE OF FOREIGN ASSETS CONTROL
DIRECTIVE 4 (AS AMENDED)[1]
UNDER EXECUTIVE ORDER 14024
Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation
Pursuant to sections 1(a)(iv), 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 has determined, in consultation with the Department of State, that the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation are political subdivisions, agencies, or instrumentalities of the Government of the Russian Federation, and that the following activities by a United States person are prohibited, except to the extent provided by law,...
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1) See related FAQs: FAQ # 998, FAQ # 999, FAQ # 1000, FAQ # 1001, FAQ # 1002, FAQ # 1003, FAQ # 1004, FAQ # 1005 and FAQ # 1118 (in re: "exit tax"). See in particular FAQ # 1005, providing guidance suggesting that the prohibition is narrower than the blocking prohibition, at least in some respects, and FAQ # 1118. See also Russia-related GL 13
2) RELATIONSHIP TO BLOCKING PROHIBITION
Note that neither "transaction" nor "transaction involving" are defined terms of art, but the totality of OFAC's guidance related to Directive 4 suggests that "transaction involving" includes the provision/receipt...