OFAC FAQ (Current) # 919 - CBW Act

Date issued: Mar. 02 2022

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TURBOFAC Commentary (115 words)

Notes:

1) The State Department announced CBW Act-related sanctions on August 20, 2021 at https://www.state.gov/fact-sheet-united-states-imposes-additional-costs-on-russia-for-the-poisoning-of-aleksey-navalny (https://archive.ph/xlbIl). The announcement, however, does not appear to include any reference to the bank loan-related sanctions previously imposed by OFAC. In any event, the FAQ aims to convey that State Department's announcement is of no consequence for ordinary compliance purposes since the scope of the sanctions imposed by the two agencies is identical.

2) FAQ updated on 3-2-2022 to add references to "Russia-related directives under Executive Order (E.O.) 14024" (i.e. directives 1 and 4 under EO 14024).