Except as authorized under General License (GL) 9A (see FAQ 981), U.S. persons may not buy or sell debt or equity of the Russian financial institutions blocked in February 2022 pursuant to Executive Order (E.O.) 14024. Accordingly, a U.S. fund may not buy, sell, or otherwise engage in transactions related to debt or equity of the blocked Russian financial institutions and must block such holdings, unless exempt, authorized under GL 9A or separately authorized by the Office of Foreign Assets Control (OFAC). However, a U.S. fund that contains such blocked holdings generally is not itself considered a blocked entity as long as the blocked holdings represent less than a predominant share by value of debt or equity of blocked persons. As a result, U.S. persons may continue to invest in the fund and the fund may continue to operate. The fund may divest itself of blocked holdings as authorized under GL 9A or separately authorized by OFAC.
Date Updated: March 02, 2022