OFAC FAQ (Current) # 998 - Russian Harmful Foreign Activities Sanctions (PDF contains all versions)

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 (132 words)

Notes:

1) See Directive 4 Under 14024, which is unique to the RHFASR. The reference to "trade or financial transactions and other dealings" suggests that while the Directive 4 entities are not blocked, the transaction prohibition that apply to them are as broad as those applied to blocked entities. But see FAQ # 1005, confirming that this is not necessarily the case.

The "indirect" transactions guidance makes explicit what OFAC considers to be implicit in all -based sanctions laws.

2) FAQ amended on 5-19-23 to add a paragraph referencing the reporting requirement added to Directive 4 on 5-19-23.

3) See comments to Directive 4 Under EO 14024 for a discussion on the unusual scope of the reporting requirement given...

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OFAC FAQ (Current) # 998 - Russian Harmful Foreign Activities Sanctions (PDF contains all versions)

TURBOFAC Commentary (132 words)