No. The prohibitions of Directive 1 under E.O. of April 15, 2021 apply only to certain bonds issued by, or loans made 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. The prohibitions in Directive 1 do not apply to any entity that is owned, directly or indirectly, 50 percent or more by one or more of these three entities, whether individually or in the aggregate.
April 15, 2021