OFAC FAQ (Current) # 1062 - 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 (274 words)

Notes:

1.1) See sections III and IV 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.

1.2) Query: how it is possible to be U.S. subsidiary of a Russian entity without providing any of the services described in FAQ # 1034? OFAC would presumably not consider all services provided to a U.S. subsidiary (e.g. accounting, tax) to be indirectly exported to Russia. For U.S. branches of Russian entities, however, it may be difficult to distinguish between the U.S.-sited operation and the actual Russian headquarters, and it is difficult to see how any U.S. branch of a Russian entity could survive without any of the services covered by the EO 14071 May 8 service ban....

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OFAC FAQ (Current) # 1062 - Russian Harmful Foreign Activities Sanctions (PDF contains all versions)

TURBOFAC Commentary (274 words)