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

Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.

Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.

TURBOFAC Commentary (211 words)

Notes:

1) With respect to the third paragraph “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 Updated 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, this was updated on 6-12-24 to reflect OFAC’s expansion of the definition of “Russia’s military-industrial base” to include “all persons blocked pursuant to E.O. 14024 [for any reason]” and “as well as any person operating in” one of the six specified sectors of the Russian economy. The FAQ was also updated to add the “directly or indirectly” clarifying text with respect to persons supporting the sale of...

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

TURBOFAC Commentary (211 words)