OFAC FAQ (Current) # 1005 - Russian Harmful Foreign Activities Sanctions (PDF contains 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 (463 words)

Notes:

1) This FAQ suggests substantial limitations on the scope of Directive 4 given the language of Directive 4, general licenses dealing with the Central Bank of the Russian Federation, and other FAQs that appear designed to suggest that the Central Bank of the Russian Federation is subject to blocking-like prohibitions, but without the obligation to block property in which the bank has an "interest". Here, OFAC confirms that this is not the case. "[T]rading in the secondary markets for debt or equity of the Central Bank of the Russian Federation...provided that no Directive 4 entity is a counterparty to such a transaction" would unmistakably be a transaction in which a transaction in which the Central Bank of the Russian Federation has an "interest," i.e. prohibited in principle is the Central Bank of the Russian Federation were a blocked person. This raises questions as to what else...