President Joseph R. Biden signed an Executive Order ("EO") blocking all property and interests in property of any person determined to have engaged in "specified harmful foreign activities" on behalf of the Government of the Russian Federation.
The EO provides that the Secretary of the Treasury, in consultation with the Secretary of State, may sanction, among others, the following persons:
Under this EO, OFAC issued Directive 1 specifying that, as of June 14, 2021, U.S. financial institutions will be prohibited from engaging with the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation and the Ministry of Finance of the Russian Federation through (i) participation in the primary market for ruble or non-ruble denominated bonds issued after June 14, 2021, and (ii) lending ruble or non-ruble denominated funds.
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