OFAC FAQ (Current) # 1118 - Russian Harmful Foreign Activities Sanctions (All versions included)

Date issued: May. 19 2023

You've hit a wall. Sign in if you have an account, learn more about TURBOFAC and subscription options, or purchase access to the text of the document on this page, the native .pdf file, and the associated TURBOFAC original commentary.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (2201 words)

Notes:

1) BACKGROUND

As conveyed by OFAC in the body of the question of the 3-30-23 version of the FAQ, “the Government of the Russian Federation may require a so-called ‘exit tax’ payment prior to the divestment of assets located in the Russian Federation,” and such taxes may “potentially requir[e] transactions involving the Central Bank of the Russian Federation or the Ministry of Finance of the Russian Federation.”

More specifically, there is a “Government Commission on Monitoring Foreign Investment,” which involves various government agencies (http://government.ru/en/info/1027/), and a separate “subcommittee” of that Government Commission that administers the divestment approval and exit tax assessment process (https://minfin.gov.ru/common/upload/library/2022/03/main/09_03_2022__1-36914.pdf).

The subcommittee was set up in March, 2022 and was (and as of 3-31-23 is) headed by the SDN Minister of Finance, Anton Siluanov (https://minfin.gov.ru/ru/permission/79-81)....