OFAC FAQ (Current) # 888 - Ukraine-/Russia-related Sanctions

Date issued: Mar. 02 2022

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TURBOFAC Commentary (106 words)

Notes:

1) See Consolidated Comment on the Russia-related Lending Directives. This FAQ essentially restates the text of Directive 1A Under Executive Order 14024 (amended on 2-22-2022 to account for Directive 1A superseding the initial Directive.

In the amended FAQ, OFAC raises the possibility that transactions otherwise prohibited by the Directive could be "exempt". Standard IEEPA exemptions apply to EO 14024, but the EO also has an "official business" exemption that applies to the USG and the UN and its associated agencies. This exemption may prove significant.

[3-2-22 update - FAQ amended to account for the issuance of Directive 4 Under EO 14024.]