OFAC FAQ (Current) # 1214 - Russian Harmful Foreign Activities Sanctions

Date issued: Jan. 10 2025

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TURBOFAC Commentary (123 words)

Notes:

1) This FAQ highlights the distinction between a primary sanctions prohibition and an authority to impose sanctions on persons for conduct with no U.S. nexus. Refer to General Note on "Sectoral Sanctions" and Determinations Made Pursuant to EOs Providing for the Blocking of Persons Determined to "Operate In" a Certain Sector. The FAQ uses the construction "exposes persons that operate or have operated in an identified sector to sanctions risk," but it is not clear whether and to what extent OFAC actually intends on sanctioning non-U.S., non-Russian persons (pursuant to 1-10-25 Energy Sector Determination) for such conduct where it has no U.S. nexus and is not otherwise unlawful. Compare FAQ # 964, FAQ # 1037, FAQ # 1085 and FAQ # 1116.