OFAC FAQ (Current) # 1131 - Russian Harmful Foreign Activities Sanctions

Date issued: Aug. 11 2023

Last substantive commentary amendment:
Sep. 09 2023

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TURBOFAC Commentary (539 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).

2)
The 50% Rule in the Context of 49.99% Ownership

As with those other cases, a modest amount of open-source research outside the four corners of the FAQ allows one to discern why OFAC would need feel the need to issue this FAQ.

LetterOne Holdings S.A. (LetterOne) is an international investment...