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RUSSIA-RELATED DIRECTIVE UNDER EXECUTIVE ORDER OF AUGUST 1, 2019 (“CBW Act Directive”)
Pursuant to sections 1(a)(ii), 1(b), and 5 of Executive Order of August 1, 2019 “Administration of Proliferation Sanctions and Amendment of Executive Order 12851” (the “Order”) and 31 C.F.R. § 544.802, and following the Secretary of State’s selection of the sanction related to bank loans pursuant to delegated authority under section 307(b) of the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991, as amended (22 U.S.C. § 5605(b)), the Director of the Office of Foreign Assets Control has determined, in consultation with the Department of State, that the following activities by a U.S. bank, as defined below, including foreign branches, are prohibited, except to the extent provided by law or unless licensed or otherwise authorized by the Office of Foreign Assets Control: (1) participation in the primary market for non-ruble denominated...
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1) Refer to Consolidated Comment on the Russia-related Lending Directives for commentary on Russia-related Directive (the "CBW Act Directive"), Directive 1 Under Executive Order of April 15, 2021 (EO 14024), the relationship between the two directives.