Frequently Asked Questions

890. Prior to June 14, 2021, are U.S. financial institutions prohibited from participating in the primary market for ruble or non-ruble denominated bonds issued by, or 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?

Answer

Even prior to June 14, 2021, U.S. banks continue to be prohibited from participating in the primary market for non-ruble denominated bonds issued by the Russian sovereign (including the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation), and from lending non-ruble denominated funds to the Russian sovereign pursuant to the Russia-Related Directive under E.O. 13883 (the “CBW Act Directive”), which was issued on August 2, 2019.  However, the CBW Act Directive does not prohibit “U.S. banks” (as defined in the CBW Act Directive) from participating in the primary market for ruble denominated bonds issued by the Russian sovereign, or the lending of ruble denominated funds to the Russian sovereign. 

Starting June 14, 2021 (when the prohibitions in Directive 1 under E.O. of April 15, 2021 come into effect), “U.S. financial institutions” (as defined in Directive 1 under E.O. of April 15, 2021) are prohibited from participating in the primary market for ruble or non-ruble denominated bonds issued by, or the lending of 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 pursuant to Directive 1 under E.O. of April 15, 2021, unless otherwise authorized by OFAC.

Note that the prohibitions found in the CBW Act Directive remain in effect and are separate from the prohibitions in Directive 1 under E.O. of April 15, 2021.  For more information on the CBW Act Directive, please see FAQs 673 - 678

Date Released
April 15, 2021