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

Date issued: May. 19 2023

You've hit a wall. Sign in if you have an account, learn more about TURBOFAC and subscription options, or purchase access to the text of the document on this page, the native .pdf file, and the associated TURBOFAC original commentary.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

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.