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OFAC updates Ukraine/Russia-related Directives

  • Europe
  • Russia
  • United Kingdom
  • Financial services disputes and investigations
  • Sanctions

05-10-2017

On 29 September 2017, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued updated Directives 1 and 2 (which were originally issued under Executive Order 13662). The updates have been made under the Countering Russian Influence in Europe and Eurasia Act of 2017, which is itself issued under Title II of the Countering America’s Adversaries Through Sanctions Act (“CAATSA”).

Directive 1 has been amended to prohibit all transactions in, provision of finance for, and other dealings in new equity, or debt issued on or after 28 November 2017 with a longer than 14 days maturity by, on behalf of or for the benefit of the persons names under the Directive, their property or their interests in property.

Directive 2 prohibits all transactions in, provision of financing for, and other dealings in new debt of longer than 60 days maturity by, on behalf of or for the benefit of the persons names under the Directive (namely specified persons operating in Russia’s energy sector), their property or their interests in property.

Transactions which are prohibited by Directives 1 and 2 must be rejected by US persons. 

A list of entities subject to Directives 1 and 2 can be found here.

OFAC has also published updated FAQs related to the Directives which can be found here.

CAATSA was signed into law by President Trump on 2 August 2017, and also contains measures related to North Korea and Iran. For further information on the Act and the sanctions measures it brings into force view our briefing of 8 August 2017.

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