OFAC has published 2 new FAQs relating to US sanctions on Ukraine & Russia. They are here.
The first FAQ addresses the ability of US persons to receive payments of principal and interest from blocked people listed in General Licences 12C, 14, and 15. It states that this is authorised, provided the loan or bond existed before 6 April 2018 and the payments are in accordance with the pre-existing loan or bond contract. It adds that the General Licences would also generally authorise the receipt of accelerated payments or voluntary prepayments, in the circumstances set out above and where they are consistent with maintenance or wind-down activities.
The second FAQ says that whether OFAC will impose sanctions on a foreign entity for paying dividends to a blocked person, where that company is not itself blocked under the 50% rule, depends on whether OFAC views the transaction as significant (see FAQs 542, 545, 579, and 589). Where the payment of dividends is done in such a way as to provide no economic benefit this will not be considered significant.