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OFAC issued Amended Directive 1 under E.O. 13662, prohibiting the following in the financial services sector of the Russian economy: “(1)
all transactions in, provision of financing for, and other dealings in new debt of longer than 30 days maturity or new equity of persons determined to be subject to this Directive, their property, or their interests in property; and (2) all activities related to debt or equity issued before the date of this Directive 1 (as amended) that would have been prohibited by the prior version of this Directive 1.” Amended Directive 1 supersedes the prior version of Directive 1 issued on July 16, 2014, thereby tightening the debt financing restrictions by reducing from 90 days to 30 days the maturity period for new debt issued by financial institutions subject to such restrictions.
Pursuant to Amended Directive 1, the entities on the SSI List in the financial services sector now include six Russian banks: Bank of Moscow, Gazprombank OAO, Russian Agricultural Bank, Sberbank, VEB and VTB Bank. As noted above,
Sberbank, the only financial institution added to the SSI List last week, is Russia’s largest bank.