OFAC FAQ (Current) # 1224 - Russian Harmful Foreign Activities Sanctions

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 (360 words)

Notes:

12-19-25 Update – FAQ amended to specify that, with respect to potential LIG divestment transactions, “OFAC expects that, at a minimum” (newly added language) the proposed transaction must “completely sever LIG’s ties with Lukoil” and “block any funds owed to Lukoil until sanctions are lifted” by “placing them in an account subject to U.S. jurisdiction" and “not provide a windfall to Lukoil, such as by providing up-front value to Lukoil, including through asset or share swaps.” Comments below pre-date the 12-19-25 FAQ amendment.

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1) FAQ interprets Russia-related 131. The GL confirms that the generally standard “maintenance or wind down of operations, contracts, or other agreements” language in GL 131 covers “transactions ordinarily incident and necessary to performing pre-existing agreements, provided that such transactions are consistent with previously established practices and support pre-existing projects or operations”. Compare...

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OFAC FAQ (Current) # 1224 - Russian Harmful Foreign Activities Sanctions

TURBOFAC Commentary (360 words)