US OFAC EO 14024 Russia Financial Services Sectoral Determination and Directives 1A, 2, 3, and 4

Mechanism

Executive Order 14024 (April 15, 2021, "Blocking Property With Respect To Specified Harmful Foreign Activities of the Government of the Russian Federation") provided the legal basis for targeting Russia's economy by sector. Following Russia's full-scale invasion of Ukraine on 24 February 2022, OFAC activated this authority through a rapid sequence of measures.

Financial Services Sectoral Determination (22 February 2022)

The Secretary of the Treasury, in consultation with the Secretary of State, determined that the financial services sector of the Russian Federation economy is subject to sanctions under EO 14024. This enables OFAC to designate any person determined to operate or to have operated in Russia's financial sector — a catch-all authority that does not require company-specific findings of malign conduct.

Directive 1A — Sovereign Debt (22 February 2022; effective 1 March 2022)

"Prohibitions Related to Certain Sovereign Debt of the Russian Federation." Prohibits US persons from participating in the primary or secondary market for ruble- or non-ruble-denominated bonds issued by the Russian sovereign after 1 March 2022. Extends and sharpens earlier sovereign-debt restrictions from the 2019-era CAATSA regime.

Directive 2 — Correspondent Accounts (24 February 2022)

"Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions." Prohibits US financial institutions from opening or maintaining correspondent or payable-through accounts for, or processing transactions involving, designated Russian financial institutions — including Sberbank, Alfa-Bank, Bank Otkritie, Sovcombank, Novikombank, Promsvyazbank, VEB.RF, and others explicitly listed. Effectively cuts the named institutions from USD clearing.

Directive 3 — New Debt and Equity (24 February 2022; effective 26 March 2022)

"Prohibitions Related to New Debt and Equity of Certain Russia-related Entities." Prohibits US persons from dealing in new debt with a maturity greater than 14 days, or any new equity, of entities in the Russian financial services, energy, mining, defense, technology, or transportation sectors. The 30-day wind-down period was set to allow orderly unwinding of existing positions.

Directive 4 — Central Bank, NWF, Ministry of Finance (28 February 2022; immediate)

"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." Prohibits any transaction — including service of debt obligations — by US persons or within the United States involving these three entities. In coordination with the EU, UK, and G7 allies who imposed parallel freeze orders, this measure immobilized roughly USD 640 billion in Russian sovereign reserves held in Western jurisdictions. It is among the most impactful single sanctions actions ever taken against a major economy, depriving Russia of the war chest it had assembled over eight years of post-2014 sanctions-proofing.

Downstream implications

• Directive 4 immediately degraded Russia's ability to defend the ruble via foreign-exchange intervention; the ruble fell >40% in the days following.
• Directive 2 severed the named Russian banks from the USD correspondent network, fragmenting Russia's international trade settlement capacity.
• The Sectoral Determination created a standing designation authority enabling rapid follow-on designations of Russian financial-sector entities without new statutory authority.
• These measures were coordinated with the EU (Council Regulation 2022/328, 2022/334), UK (OFSI), and G7 partners — the first time a G7-wide sovereign reserve freeze was executed in real time.
• Subsequent actions (OFAC GL series, EU sanctions packages 14–20) extended and refined this framework through 2025–26.

Open questions

• Litigation challenging the freeze of Russian sovereign assets in EU jurisdictions (particularly the ~EUR 300 billion held at Euroclear) remains pending before the ECJ as of early 2026.
• The legality of transferring frozen profits (not principal) to Ukraine under REPO Act / EU windfall-profit mechanisms is under active legal review.