Pursuant to Directive 1 under E.O. of April 15, 2021, “Blocking Property with Respect to Specified Harmful Foreign Activities of the Government of the Russian Federation,” the following activities by a U.S. financial institution are prohibited as of June 14, 2021:
- Participation in the primary market for ruble or non-ruble denominated bonds issued after June 14, 2021 by the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation; and
- Lending ruble or non-ruble denominated funds to the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, or the Ministry of Finance of the Russian Federation.
Further, except to the extent otherwise provided by law or unless licensed or otherwise authorized by OFAC, the following are also prohibited pursuant to Directive 1: (1) any transaction that evades or avoids, has the purpose of evading or avoiding, causes a violation of, or attempts to violate any of the prohibitions contained in Directive 1; and (2) any conspiracy formed to violate any of the prohibitions in Directive 1.