OFAC FAQ (Current) # 1018 - Russian Harmful Foreign Activities Sanctions (PDF contains all versions)

Date issued: Mar. 08 2022

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TURBOFAC Commentary (75 words)

Notes:

1) Refer generally to comments to EO 14066.

This is a roundabout way of saying that EO 14066 does not contain any provision that could apply to transactions with no U.S. nexus whatsoever (i.e. the prohibitions do not apply, and there are no designation criteria in the EO). However, transactions described by this EO might, for example, entail "material assistance" to persons blocked pursuant to EO 14024 or EO 13662 (e.g. provision of credit).