OFAC FAQ (Current) # 1202 - Russian Harmful Foreign Activities Sanctions

Date issued: Nov. 21 2024

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TURBOFAC Commentary (499 words)

Notes:

1) This FAQ was issued in connection with OFAC’s sweeping designation package that targeted a large number of previously non-blocked smaller institution, including the ~40 listed on the annex to Russia-related GL 113. The purpose of this FAQ appears to be to convey that, notwithstanding the scope of the 11-21-24 blocking action, OFAC did not intend to completely cut Russia off from the U.S.-linked financial system, such that “[t]here remain a number of non-sanctioned Russian banks” and transactions involving such banks may require no authorization because they are “not otherwise prohibited by OFAC” (in addition to the authorizations that exist for otherwise prohibited transactions).

2) The specific question addressed is whether OFAC’s 11-21-24 bank designations will “impact the processing of personal, non-commercial remittances to or from Russia”. The answer is “no”. OFAC has fully blocked a...