OFAC FAQ (Current) # 967 - 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 (360 words)

Notes:

1) This is a general overview of Directive 2 Under 14024. See associated FAQs. The FAQ does not provide much in the way of "interpretive guidance." Note the reference to "foreign financial institutions subject to the prohibitions of the Russia-related Directive [] also [] subject to additional prohibitions under other sanctions authorities, such as additional directives under E.O. 14024 or E.O. 13662." This is currently the case with Sberbank (subject to SSI Directive 1).

2) Amended on 3-2-2022 to add the following paragraph:

Accordingly, after the relevant effective date, U.S. financial institutions must reject any transaction involving a foreign financial institution determined to be subject to the prohibitions of the Russia-related CAPTA Directive or involving that foreign financial institution’s property or interests in property.

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OFAC FAQ (Current) # 967 - Russian Harmful Foreign Activities Sanctions (PDF contains all versions)

TURBOFAC Commentary (360 words)