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

Date issued: Dec. 22 2023

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TURBOFAC Commentary (92 words)

Notes:

1) This FAQ clarifies 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. Note however that even if a person is designated for operating in a sector of the Russian economy that is not subject to subsection 11(a)(ii) of EO 14024, there is still a “material support” authority that can be used to sanction the FFI.