OFAC Tightens Russian Sectoral Sanctions

By: Michael T. Gershberg, Justin A. Schenck

On September 29, 2017, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) revised its prohibitions on dealings in new debt under the Russian sectoral sanctions.  The amended Directive 1, covering the financial sector, reduces the tenor for new debt to 14 days (from 30 days).  The amended Directive 2, covering the energy sector, reduces the tenor to 60 days (from 90 days).  These revisions were made pursuant to the Countering Russian Influence in Europe and Eurasia Act of 2017 (CRIEEA), part of the recent omnibus sanctions legislation, the Countering America's Adversaries Through Sanctions Act (CAATSA).  The changes take effect for new debt issued on or after November 28, 2017.

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