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 transactions within the United States involving derivative products whose value is linked to an underlying asset that constitutes prohibited” debt issued by a party subject to the debt prohibitions of OFAC Directives 1, 2, or 3 or prohibited equity under Directive 1.[ii] As explained by OFAC, the changes implemented by General License 1B “relate to… Read More Continue Reading

OFAC DIRECTIVE 1 AS AMENDED SEPTEMBER 29, 2017

Business Update | October 11, 2017 | Author: Hdeel Abdelhady | PDF OFAC Further Tightens Russia Debt Prohibitions Pursuant to the Countering Russian Influence in Europe and Eurasia Act of 2017 As required by the Countering Russian Influence in Europe and Eurasia Act of 2017 (CRIEEA),[i] the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) on September 29, 2017 amended and reissued OFAC Directive 1 (Directive 1).[ii] As amended, Directive 1 continues to prohibit certain “new” debt, equity, and related transactions involving entities subject to U.S. Sectoral Sanctions targeting Russia’s financial services sector. This Business Update discusses the background to and mechanics of Directive 1 as amended and reissued. Ukraine/Russia-Related… Read More

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