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October 2017

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On September 29, 2017, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) amended and reissued Directive 1 and Directive 2 implementing US sectoral sanctions targeting Russia pursuant to the Countering America’s Adversaries Through Sanctions Act (“CAATSA”). The maturity of prohibited “new debt” under Directive 1 will be reduced to 14 days (from 30 days) and the maturity of prohibited “new debt” under Directive 2 will be reduced to 60 days (from 90 days).