OFAC FAQ (Current) # 1104 - Russian Harmful Foreign Activities Sanctions

Date issued: Dec. 15 2022

Last substantive commentary amendment:
Aug. 13 2023

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TURBOFAC Commentary (145 words)

Notes:

1) This FAQ is one of several FAQs published by OFAC assuring the regulated public that one or more entities in which sanctioned individuals have or have had a significant ownership stake are not blocked—pursuant to the 50% Rule or otherwise–as a result of such individuals being pursuant to the RuHSR. As of 8-13-23 these are FAQ # 1073, FAQ # 1074, FAQ # 1075, FAQ # 1104, FAQ # 1129 and FAQ # 1131). Here, Vladimir Potanin was the President and Chairman of the Management Board of Norilsk Nickel, and a 36.14% shareholder as of the date of the designation. (https://www.nornickel.com/investors/shareholders/listing as of 12-16-22). While Potanin may "control" Norilsk Nickel, "OFAC’s 50 Percent Rule speaks only to ownership and not to control." (FAQ # 398).
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