Ukraine/Russia Sanctions: OFAC Authorizes Derivatives Linked to Prohibited Debt and Equity Under OFAC Directives 1, 2 or 3

Ukraine/Russia Sanctions: OFAC General License No. 1B Authorizes Derivative Transactions Linked to Prohibited Debt Under OFAC Directives 1, 2 or 3 On November 28, 2017, the Treasury Department’s Office of Foreign Assets Control (OFAC) issued General License No. 1B under Executive Order 13,662.[i] General License 1B authorizes “[a]ll transactions by U.S. persons, wherever located, and…

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