OFAC FAQ (Current) # 1066 - Russian Harmful Foreign Activities Sanctions

Date issued: Jun. 09 2022

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TURBOFAC Commentary (88 words)

Notes:

1) This rare interpretation of the scope of the standard "evade/avoid" prohibition appears aimed at addressing a situation in which (for example) bespoke accounting services are provided under the guise of education. Compare General Note on the Apparent Scope of "Evasion/Avoidance" Provisions.

2) 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.