OFAC FAQ (Current) # 1002 - Russian Harmful Foreign Activities Sanctions (PDF contains all versions)

Date issued: May. 19 2023

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TURBOFAC Commentary (72 words)

Notes:

1) The "indirect" transactions guidance makes explicit what OFAC considers to be implicit in all IEEPA-based sanctions laws. The FAQ is notable for the signal of heightened diligence expectations.

2) FAQ amended on 5-19-23 to add "as amended" the full name of Directive 4, and to clarify that "debiting funds from restricted accounts" is prohibited by Directive 4. This is a clarifying amendment, rather than a substantive change.