OFAC FAQ (Current) # 1010 - Russian Harmful Foreign Activities Sanctions (PDF contains all versions)

Date issued: Jun. 14 2022

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TURBOFAC Commentary (248 words)

Notes:

1) Crucial guidance clarifying that GL 8 also covers "financing, loading, or unloading related to such processes".

2) FAQ substantially amended on 3-8-22 to account for EO 14066.

The following paragraph is key:

E.O. of March 8, 2022 does not prohibit transactions such as the unwinding of contracts or other business-related activities by U.S. persons to comply with the import ban imposed under E.O. of March 8, 2022. Likewise, E.O. of March 8, 2022 does not prohibit U.S. persons from engaging in transactions to sell or re-direct shipments that were laden on or after March 8, 2022 and previously destined for the United States. The Office of Foreign Assets Control (OFAC) has also authorized until April 22, 2022 certain transactions prohibited by E.O. of March 8, 2022 (see FAQs 1013 – 1020).