OFAC FAQ (Current) # 1204 - Russian Harmful Foreign Activities Sanctions

Date issued: Dec. 27 2024

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TURBOFAC Commentary (73 words)

Notes:

1) Read in conjunction with Russia-related GL 116, and comments thereto. This FAQ clarifies that the GL does not authorize transactions “transactions or other dealings involving Ivanishvili” other than “transactions or other dealings with entities owned by Ivanishvili that are not listed on OFAC's [SDN List],” and that there is no secondary sanctions risk for dealings of non-U.S. persons that would have been authorized for U.S. persons (compare FAQ # 980).