OFAC FAQ (Current) # 970 - Russian Harmful Foreign Activities Sanctions

Date issued: Feb. 24 2022

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TURBOFAC Commentary (203 words)

Notes:

1) The FAQ appears to confirm -- with the reference to "by one or more FFIs determined to be subject to the prohibitions of the Russia-related CAPTA Directive" -- that the 50% rule does not apply "across directives". This is the case with the SSI Directives as well.

2) Note that the limitation of the directive to "foreign financial institutions" appears to be an outgrowth of FinCEN's definition of "correspondent account".

See 31 CFR § 1010.605(c):

(c) Correspondent account. (1) The term correspondent account means:
(i) For purposes of § 1010.610(a), (d) and (e), an account established for a foreign financial institution to receive deposits from, or to make payments or other disbursements on behalf of, the foreign financial institution, or to handle other financial transactions related...