U.S. Sanctions by the United States Department of the Treasury pursuant to the CBW Act


Clearstream Banking1 informs customers that, pursuant to the CBW Act, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a Russia-related Directive (CBW Act Directive). The CBW Act Directive had an effective date of 26 August 2019.

The CBW Act Directive restricts U.S. banks from engaging in:

  • participation in the primary market for non-Rouble denominated bonds issued by the Russian sovereign after 26 August 2019; and
  • lending non-Rouble denominated funds to the Russian sovereign after 26 August 2019.

The following are also prohibited:

  • any transaction that evades or avoids, has the purpose of evading or avoiding, causes a violation of, or attempts to violate any of the prohibitions contained in the CBW Act Directive; and
  • any conspiracy formed to violate any of the prohibitions in the CBW Act Directive.

Primary market

Clearstream Banking is monitoring any new issuances in respect of the above.

Secondary market

The CBW Act Directive does not prohibit U.S. banks from participating in the secondary market for Russian sovereign debt.

Income and corporate events

In respect of expected forthcoming corporate or income events on existing eligible securities which may fall into this category, these will be monitored and reviewed in cooperation with the relevant depositories or paying agents.

Further information

For further information, customers may contact Clearstream Banking Client Services or their Relationship Officer.


1. Clearstream Banking refers to Clearstream Banking AG, registered office at 61, Mergenthalerallee, 65760 Eschborn, Germany and registered in Register B of the Amtsgericht Frankfurt am Main, Germany under number HRB 7500.