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

Date issued: Jun. 09 2022

You've hit a wall. Sign in if you have an account, or learn more about TURBOFAC and subscription options.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (85 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.