OFAC FAQ (Current) # 1009 - Ukraine-/Russia-related Sanctions (PDF contains all versions)

Date issued: May. 05 2022

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TURBOFAC Commentary (235 words)

Notes:

1) Compare FAQ # 932, suggesting to virtually all readers that one can visit the shrine, but not actually saying so explicitly. Here the FAQ says that the EO does not "block the entire Donetsk and Luhansk oblasts," but the EO does not block any territory at all.

The scope of the section 1 embargo remains unclear, except that the FAQ can be said to serve as further evidence that the embargo does not cover all areas "claimed" by the DPR/LPR even where such areas are not actually controlled by Russian Government forces or the separatists.

Note that this FAQ was first issued on 05/05/2022, and it was amended on May 05, 2022 to (i) have "activity that does not involve the Covered Regions" replace "activity outside the Covered Regions" (this...