OFAC FAQ (Current) # 1063 - Russian Harmful Foreign Activities Sanctions

Date issued: Jun. 09 2022

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TURBOFAC Commentary (88 words)

Notes:

1) Here OFAC highlights a key distinction between the EO 14071 new investment ban and the EO 14071 service ban of May 8, i.e. that the former has an exclusion (via FAQ) for "maintenance" of pre-existing operations, while the service prohibition does not.

2) See section IV(c) 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.