OFAC FAQ (Current) # 1225 - Russian Harmful Foreign Activities Sanctions

Date issued: Dec. 04 2025

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TURBOFAC Commentary (155 words)

Notes:

1) See comments to Russia-related GL 128 for discussion on how this FAQ relates to the scope of Russia-related GL 128.

2) With respect to the secondary sanctions safe harbor guidance, which applies to this GL and Russia-related General License 131 OFAC provides the standard guidance that “non-U.S. persons generally do not risk exposure to U.S. sanctions under E.O. 14024 for engaging in transactions with blocked persons that are generally authorized for U.S. persons” (compare FAQ # 980), and specifies further that the GLs may be relied upon by FFIs engaging in otherwise sanctionable activity even if not operating “blocked accounts” (i.e. paragraph (b) provides authorization to use blocked accounts in connection with authorized activities, it does not require that). The FAQ is notable for specifying that, in order for the...