OFAC FAQ (Current) # 1025 - Russian Harmful Foreign Activities Sanctions (PDF contans all versions)

Date issued: Feb. 23 2024

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TURBOFAC Commentary (278 words)

Notes:

* FAQ amended on 2-23-24 to update references to GL 6C (from GL 6), and to add the last paragraph. The substance of that final paragraph simply affirms that GL 6C does not license against the import prohibitions of EO 14068. The comments below have not yet been amended to reflect the 2-23-24 changes.

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1) "Fish, seafood, and preparations thereof" are subject to the import ban in EO 14068, while Russia-related General License 6 authorizes "all transactions prohibited by Executive Order (E.O.) 14024 that are ordinarily incident and necessary to: [] the exportation or reexportation of agricultural commodities…to, from, or transiting the Russian Federation…”

First note that EO 14024 and EO 14068 are separate authorities, and Russia-related General License 6 does not authorize any transaction otherwise prohibited by...