OFAC FAQ (Current) # 1151 - Russian Harmful Foreign Activities Sanctions

Date issued: Dec. 22 2023

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TURBOFAC Commentary (269 words)

Notes:

1) Refer generally to comments to EO 14114 for more on the new section 11 of EO 14024. The “significant transaction or transactions” portion of this guidance generally tracks the standard guidance and/or interpretive provision defining “significant transaction” for secondary sanctions purposes. See e.g. 510.413, and see Guidance for Foreign Financial Institutions on OFAC Sanctions Authorities Targeting Support to Russia’s Military-Industrial Base for examples of transaction types that OFAC appears to specifically be targeting.

2) With respect to the second paragraph, note that section 11 of amended EO 14024 allows for sanctions against FFIs conducting transactions “involving Russia’s military-industrial base, including the sale, supply, or transfer, directly or indirectly, to the Russian Federation of any item or class of items as may be determined…” Here, OFAC defines “Russia’s military-industrial base” such that...