OFAC FAQ (Current) # 1055 - Russian Harmful Foreign Activities Sanctions (PDF contains all versions)

Date issued: Jan. 17 2023

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TURBOFAC Commentary (204 words)

Notes:

1) Refer to section 6 of Russia-related New Investment System Note for an in-depth discussion of this FAQ and the notion of "new investment" as applied to dealings with non-sanctioned third country companies.

2) See Russia-related GL 54, and comments thereto. GL 54 implicitly interprets this FAQ in a number of notable ways.

3) This FAQ was amended on 1-17-23 in a way that had a significant impact on the scope of the new investment prohibition. Among other changes, OFAC substituted "predominantly derived from its investments in the Russian Federation" for "than 50 percent…from its investments in the Russian Federation." that this change was made concurrent with the amendment of three other Russia-related FAQs (FAQ # 982, FAQ # 1054 and FAQ # 1059), all three of...