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

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 (459 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....

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

TURBOFAC Commentary (459 words)