OFAC FAQ (Current) # 1086 - Russian Harmful Foreign Activities Sanctions

Date issued: Sep. 15 2022

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TURBOFAC Commentary (147 words)

Notes:

1) See FAQ # 1084 for the services prohibition equivalent of this FAQ. The primary difference is that “quantum computing sector of the Russian Federation economy” includes the actual exportation of goods themselves, as opposed to just services related to such exportation, and it also apparently includes the receipt of goods from Russia.

The receipt of goods from non-sanctioned individuals is not prohibited by any OFAC-administered primary sanctions prohibition active as of the date on which this FAQ was issued. Does this mean that non-U.S. persons can be designated for such activities even though they aren’t prohibited for U.S. persons? Presumably note. See FAQ # 980 (“Moreover, non-U.S. persons generally do not risk exposure to U.S. blocking sanctions under E.O. 14024 for engaging in transactions with blocked persons, where those transactions would not require a...