OFAC FAQ (Current) # 1030 - Russian Harmful Foreign Activities Sanctions

Date issued: Apr. 20 2022

You've hit a wall. Sign in if you have an account, learn more about TURBOFAC and subscription options, or purchase access to the text of the document on this page, the native .pdf file, and the associated TURBOFAC original commentary.

TURBOFAC Commentary (473 words)

Notes:

1) This FAQ appears directly aimed at China-based UnionPay, which is accepted along with Visa and Mastercard at many locations in the U.S. See e.g. https://interfax.com/newsroom/top-stories/75735/ (Sberbank working to issue MIR, China's UnionPay co-badged payment cards after Visa, MasterCard announce exit from Russia).

2) In one sentence, OFAC acknowledges that "U.S. operators of credit card systems" can process transactions involving sanctioned financial institutions where such transactions are "exempt or authorized by OFAC". Such transactions would include, for example, those ordinarily incident to travel. In the next paragraph, OFAC suggests that "non-U.S. operators of credit card systems" should (but are apparently not required to) "prevent the use of payment cards issued by sanctioned foreign financial institutions in the United States at the network level." This would obviously make it impossible to use such cards even for exempt or authorized transactions....