No. The Russia-related Entities Directive prohibits U.S. persons from engaging in only certain activities related to new debt of longer than 14 days maturity or new equity of the entities listed in Annex 1 to the Russia-related Entities Directive, or of entities otherwise determined to be subject to the prohibitions of the Russia-related Entities Directive, as explained in FAQ 984. Please see FAQ 985 regarding the applicability of OFAC’s 50 Percent Rule with respect to this directive.
Some entities determined to be subject to the prohibitions of the Russia-related Entities Directive may also be subject to additional prohibitions under other sanctions authorities, such as additional directives under E.O. 14024 or E.O. 13662. It is important to note that each directive operates independently of the others. For example, if a transaction involves a person subject to two separate directives, a U.S. person engaging in that transaction must comply with both directives.