OFAC FAQ (Current) # 1117 - Russian Harmful Foreign Activities Sanctions

Date issued: Feb. 24 2023

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TURBOFAC Commentary (356 words)

Notes:

1) See Determination Pursuant to Section 1(a)(i) of Executive Order 14024 (Effective February 24, 2023) and read in conjunction with related FAQ # 1114, FAQ # 1115, FAQ # 1116 and FAQ # 1117.

2) This FAQ confirms that "operating in" a given sector can, in principle, consist merely of "provid[ing] goods or services to, or engag[ing] in trade with, persons that operate or have operated in the metals and mining sector of the Russian Federation economy". This is not new (see generally General Note on "Sectoral Sanctions" and Determinations Made Pursuant to EOs Providing for the Blocking of Persons Determined to "Operate In" a Certain Sector).

The FAQ provides a safe harbor from sanctions risk where "the provision of goods or services is solely for the safety and care...