OFAC FAQ (Current) # 1029 - Russian Harmful Foreign Activities Sanctions (PDF contains all versions)

Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.

Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.

TURBOFAC Commentary (153 words)

Notes:

1) This FAQ appears to serve three primary purposes: First, it is looks as if it is a 'policy statement' signaling that OFAC may make designations under the 14024 derivative designation criteria for gold and other related transactions even where there is no U.S. nexus to the transaction, and in the case of transactions involving blocked persons, even where the transactions are not 'structured' or otherwise deceptive. Second, this appears to be the first time that OFAC has explicitly stated that "conspiring to cause" a sanctions violation is unlawful, even if the actual conspiracy involved no U.S. person. OFAC appeared to rely in part on a "conspiracy to cause" theory of liability in Settlement Agreement (OFAC) - Ericsson, Inc. and Ericsson AB, but this was not made explicit.

2) Amended on 6-28-22 to add the...

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OFAC FAQ (Current) # 1029 - Russian Harmful Foreign Activities Sanctions (PDF contains all versions)

TURBOFAC Commentary (153 words)