The U.S. Department of the Treasury Office of Foreign Assets Control ("OFAC") issued amended Directives and frequently asked questions ("FAQs") in connection with the Ukraine/Russia-related sanctions program.
Under the Countering America's Adversaries Through Sanctions Act, OFAC was required to strengthen sectoral sanctions against certain Russian industries (see previous coverage). Directive 1 targets the Russian financial sector, and prohibits dealing in debt and equity connected to certain prohibited Russian persons. It supersedes previous versions of the directive, and reduces the tenor of debt necessary to qualify for prohibition to 14 days maturity, effective November 28, 2017 (which was originally 90 days, then reduced to 60 days beginning on September 12, 2014).
Directive 2 targets individuals in the Russian energy sector, and will reduce the tenor of prohibited debt from 90 days maturity to 60 days for debt issued from November 28, 2017 forward.
The updated FAQs answer questions relevant to the amended Ukraine/Russia-related sanctions.
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