OFAC FAQ (Current) # 1092 - Russian Harmful Foreign Activities Sanctions (PDF contains all versions)

Date issued: Feb. 23 2024

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TURBOFAC Commentary (257 words)

Notes:

1) Like a "statement of licensing policy" is an articulation, by OFAC, of a non-binding intent to exercise its inherent discretion to issue specific licenses for certain categories of activities, this FAQ and otherwise like it functions as an effective "statement of sanctioning policy." Here, OFAC points to the broad "material support" and "operating in" designation criteria found in EO 14024 and provides notice that these designation criteria will be used to sanction non-U.S. persons for activities otherwise outside the scope of OFAC's primary sanctions jurisdiction. In addition, OFAC specifies that "operate or have operated in the defense and related materiel sector of the Russian Federation economy" will cover persons determined to "engage in the provision of ammunition or other military goods to the Russian Federation, including persons determined to operate or have operated in the arms or related materiel sector of the Russian...