U.S. publication of new and amended Russia-related FAQs

New and amended Russia-related “frequently asked questions”

New and amended Russia-related “frequently asked questions”

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) today issued new and amended Russia-related “frequently asked questions” (FAQs).

Read the new FAQs (answers provided at link):

  • 1055. Do the new investment prohibitions of Executive Order (E.O.) 14066, E.O. 14068, or E.O. 14071 (collectively, “the respective E.O.s”) prohibit U.S. persons from lending funds to, or purchasing an equity interest in, entities located outside of the Russian Federation? 
  • 1054. Do the new investment prohibitions of Executive Order (E.O.) 14066, E.O. 14068, or E.O. 14071 (collectively, “the respective E.O.s”) prohibit U.S. persons from purchasing debt or equity securities issued by an entity in the Russian Federation?
  • 1053. Under the new investment prohibitions of Russia-related Executive Order (E.O.) 14066, E.O. 14068, or E.O. 14071 (collectively, “the respective E.O.s”), are transactions related to divestment permissible?
  • 1052. Can U.S. persons continue to fund their subsidiaries and affiliates with projects or operations located in the Russian Federation prior to the effective dates of the new investment prohibitions of Executive Order (E.O.) 14066, E.O. 14068, or E.O. 14071 (collectively, “the respective E.O.s”)?
  • 1051. Is the export to the Russian Federation or import from the Russian Federation of goods, services, or technology considered “new investment” for the purposes of Russia-related Executive Order (E.O.) 14066, E.O. 14068, or E.O. 14071 (collectively, “the respective E.O.s”)?
  • 1050. What types of transactions are considered to be “maintenance” activities described in FAQ 1049 and therefore outside the scope of the “new investment” prohibitions of Russia-related Executive Order (E.O.) 14066, E.O. 14068, or E.O. 14071 (collectively, “the respective E.O.s”)?
  • 1049. For the purposes of Russia-related Executive Order (E.O.) 14066, E.O. 14068, or E.O. 14071 (collectively, “the respective E.O.s”), what is meant by the term “new investment”?
     

Read the amended FAQs (answers provided at link):

  • 1019. For the purposes of Executive Order (E.O.) 14066, what is meant by the term “Russian Federation origin”?
  • 1005. Does Directive 4 under Executive Order (E.O.) 14024, “Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation” (Russia-related Sovereign Transactions Directive) prohibit trading in the secondary markets for Russian sovereign debt?

 

For more information on sanctions and other responses to Russia’s war on Ukraine, visit KPMG’s dedicated website.

Contact a professional with KPMG’s Trade & Customs services:

Doug Zuvich
Partner and Global Practice Leader
E: dzuvich@kpmg.com

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Principal and East Coast Leader
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Partner and National Practice Leader
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Steve Brotherton
Principal and Global Export and Sanctions Leader
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Luis (Lou) Abad
Principal, Washington National Tax
E: labad@kpmg.com

Irina Vaysfeld
Principal
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Amie Ahanchian
Principal
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Christopher Young
Principal
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Principal
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Principal
E: gzaharatos@kpmg.com

Andy Doornaert
Managing Director
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Jessica Libby
Principal
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