OFAC FAQ (Current) # 1019 - Russian Harmful Foreign Activities Sanctions (PDF contains all versions)

Date issued: Apr. 12 2024

Last substantive commentary amendment:
Apr. 14 2024

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TURBOFAC Commentary (1565 words)

Notes:

[11-22-22 Update - On 11-22-22, OFAC issued its OFAC Guidance on Implementation of the Price Cap Policy for Crude Oil of Russian Federation Origin, with comments on "blends" that are not inconsistent with the below, but do at least raise concerns that "incorporation...into a foreign made product" does not apply in the "Price Cap" context as it does in the EO 14066 context. See section II(b)(i) of Consolidated Comment on the Prohibitions on Certain Services as They Relate to the Maritime Transport of Crude Oil of Russian Federation Origin (the Price Cap). Note that this item has been tagged as relating to both EO 14066 and EO 14071 (Price Cap) due to its implications for the meaning of "Russian Federation origin" for Price Cap purposes.]

[2-23-23 Update - FAQ amended on 2-23-24 to specify that the...