OFAC FAQ (Current) # 1081 - Russian Harmful Foreign Activities Sanctions

Date issued: Sep. 15 2022

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TURBOFAC Commentary (240 words)

Notes:

1) It is not clear whether this FAQ is simply clarifying that the lump funds transfer portion of Russia-related GL 50 does not require a showing of “official documentation” that the account at issue has been closed, or whether GL 50 operates such that funds in blocked accounts can be transferred even if the account has not actually been closed. Note use of the term “remaining” in the authorization section below.

Except as provided in paragraph (b) of this general license, all transactions prohibited by Executive Order (E.O.) 14024 that are ordinarily incident and necessary to (i) the closing of an account of an individual, wherever located, who is not a blocked person (“the account holder”), held at a financial institution blocked pursuant to E.O. 14024, and (ii) the unblocking and lump sum transfer of all remaining...