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ARTICLE · 09 OCTOBER 2017

Implementing CAATSA - OFAC Issues Amended Russian-Related Sectoral Sanctions Under Directives 1 And 2

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On September 29, 2017, the U.S. Department of the Treasury's OFAC issued amended directives shortening the permissible maturity windows of new debt issued by designated financial and energy companies...

United StatesInternational Law
Wynn Segall
Wynn Segall
Jonathan Poling
Jonathan Poling
Melissa Schwartz
Melissa Schwartz
Nnedinma Ifudu Nweke
Nnedinma Ifudu Nweke
Sina Kimiagar
Sina Kimiagar
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Key Points:

  • On September 29, 2017, OFAC modified Directives 1 and 2 of Executive Order 13662 to reduce the permissible maturity for new debt issued by Russian financial and energy entities designated under these directives, as well as entities owned, directly or indirectly, by 50 percent or more by such entities, either individually or in the aggregate. These modifications become effective on November 28, 2017.
  • To ensure compliance with these changes to U.S. sectoral sanctions relating to new debt, which were required by the Countering America's Through Adversaries Act (CAATSA), U.S. persons must remain vigilant in reviewing pre-existing financial arrangements and proposed new transactions to ensure that they do not involve new debt issued by designated entities and entities owned 50 percent or more by such entities that have a maturity exceeding 14 days for entities subject to Directive 1 or 60 days for entities subject to Directive 2.

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