With respect to foreign financial institutions subject to the prohibitions of Directive 2 under E.O. 14024 , “Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions” (Russia-related CAPTA Directive ), including Public Joint Stock Company Sberbank of Russia, obligations under this directive apply to U.S. financial institutions only. U.S. individuals and companies that are not “U.S. financial institutions,” as defined in the Russia-related CAPTA Directive, are not prohibited from processing transactions involving foreign financial institutions subject to the Russia-related CAPTA Directive.
With respect to the Russian financial institutions blocked on February 22 and 24, 2022 pursuant to E.O. 14024, General Licenses (GLs) 3 and 11 authorize U.S. persons to engage in transactions ordinarily incident and necessary to terminate their relationship with specified blocked Russian financial institutions, including withdrawing funds and securities, cancelling letters of credit, and amending or cancelling performance guarantees. For additional information, please see FAQ 975. Upon the respective expiration of GLs 3 and 11, U.S. persons are prohibited from transacting with the blocked Russian financial institutions, unless exempt or authorized by OFAC.