OFAC FAQ (Current) # 1004 - Russian Harmful Foreign Activities Sanctions (PDF contains all versions)

Date issued: May. 19 2023

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TURBOFAC Commentary (97 words)

Notes:

1) Read in conjunction with FAQ # 1004. This FAQ may suggest that the CBR is subject to blocking-like sanctions minus the blocking, but the prohibitions may in practice to a range of transactions far narrower than those in which the CBR has an "interest". The "effectively immobilize any assets" language here is notable. Does a transaction in which the CBR has an interest fall within the scope of the prohibition if doesn't involve the "assets" of the CBR?

2) FAQ amended on 5-19-23 to add "as amended" the full name of Directive 4.