OFAC FAQ (Current) # 1197 - Russian Harmful Foreign Activities Sanctions (PDF contains all versions)

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 (187 words)

Notes:

1) See section 2 to General Note on the Implications of OFAC’s Blocking of the Russian National Settlement Depository (NSD) (System Ed. Note) for comments on this FAQ, and see section 1 for helpful background reading concerning the blocking of NSD generally. On 11-21-24, OFAC amended FAQ # 1197 to add the final paragraph, noting that it had “designated more than 40 local Russian registrars pursuant to E.O. 14024”. OFAC’s treatment of securities “held at these registrars” is the same as it is with respect to securities “held at” the NSD (though note the uncertainty concerning the meaning of the term “held at”, discussed at section 2(d) in the System Note.

2) OFAC says “Any U.S. persons who have already filed initial blocking reports on such securities do not need to file amended reports solely due to a change...

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OFAC FAQ (Current) # 1197 - Russian Harmful Foreign Activities Sanctions (PDF contains all versions)

TURBOFAC Commentary (187 words)