OFAC FAQ (Current) # 1058 - Russian Harmful Foreign Activities Sanctions

Date issued: Jun. 09 2022

Last substantive commentary amendment:
Jun. 12 2024

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TURBOFAC Commentary (256 words)

Notes:

1) See section II(a) of General Note on E.O. 14071-Based Prohibitions on the Exportation of Certain Services to Persons Located in Russia (System Ed. Note) for comments on the FAQ in the context of the relevant prohibitions in general.

2) Query: does this interpretation apply to individuals for the purposes of (i) the "new investment" prohibition of EO 14071 and/or the "banknote" ban in EO 14068? The FAQ says that it applies "[f]or the purposes of" section 1(a)(ii) of Executive Order 14071, but this does not mean that "person located in the Russian Federation" will be interpreted differently in other Russia related prohibitions. If a U.S. person provides a bank loan to a person "ordinarily resident in the Russian Federation," is that prohibited "new investment"?

3) In theory, this FAQ applies to the...