OFAC FAQ (Current) # 1017 - Russian Harmful Foreign Activities Sanctions

Date issued: Jun. 14 2022

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TURBOFAC Commentary (137 words)

Notes:

1) Refer generally to comments to EO 14066.

The FAQ says " GL 8A does not authorize any transactions prohibited by E.O. of March 8, 2022". Can a blocked Russian bank be used to process a transaction that is otherwise prohibited by EO 14066 but authorized by Russia-related General License 16 (e.g. letter of credit transaction involving a blocked bank related to the importation of oil into the U.S.). It seems that the answer is yes. The FAQ appears aimed at specifying that transactions otherwise described by GL 8A are not authorized by GL 8A if they are also within the scope of the prohibition of EO 14066, unless the transactions are separately authorized by EO 14066.

* FAQ amended on 6-14-22 to reference