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

Date issued: May. 19 2023

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TURBOFAC Commentary (132 words)

Notes:

1) See Directive 4 Under EO 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 IEEPA-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...