OFAC FAQ (Removed) # 1153 - Russian Harmful Foreign Activities Sanctions

Date issued: Dec. 22 2023

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TURBOFAC Commentary (216 words)

Notes:

1) This FAQ clarified that in order to determine sanctions risk under subsection 11(a)(ii) of Executive Order 14024 (as amended), one may need to cross-reference OFAC and State Department press releases to determine what sectors certain designated persons were designated for operating in.

2) FAQ removed from OFAC’s website on 6-12-24 in light of the expansion of the secondary sanctions provision at subsection 11(a)(ii) of Executive Order 14024 to include all persons blocked pursuant to EO 14024, not just those blocked for operating in certain sectors. OFAC noted (see https://ofac.treasury.gov/recent-actions/20240612) that:

[OFAC has updated the secondary sanctions language on its SDN list related to Executive Order 14024 as amended by Executive Order 14114. This language previously read:

"Secondary sanctions risk: this person is designated for operating or having operated in a...