OFAC Provides Guidance on Inherited Russian Securities

The Office of Foreign Assets Control this week published a new Russia-related frequently asked question providing guidance on Russian securities transferring through inheritance. FAQ 1113 explains that investment prohibitions under executive orders 14066, 14068 and 14071 don't prevent securities issued by non-blocked Russian entities from transferring to their beneficiaries as long as those transfers are "part of the ordinary course administration of the decedent’s estate," don't "involve an exchange for value," and "have no other sanctions nexus." Blocked securities in an estate, however, remain blocked and require a specific license from OFAC to transfer.