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

Date issued: May. 19 2023

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TURBOFAC Commentary (2154 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)....