OFAC FAQ (Current) # 974 - Russian Harmful Foreign Activities Sanctions (PDF contains all versions)

Date issued: Mar. 02 2022

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TURBOFAC Commentary (182 words)

Notes:

1) Of particular note here is the statement that "all property and interests in property of these entities in the possession or control of U.S. persons, including U.S. financial institutions, or within U.S. jurisdiction, are blocked and must be reported to OFAC." The term "property and interests in property" normally refers to all property "in which" a blocked person has an interest. See e.g. General Note on the 300-level definition of ‘Blocked account; blocked property’. However, the GLs referenced in the FAQ have the effect of authorizing transactions involving certain property in which blocked person have an interest, and the GLs took effect concurrently with the blocking. Must property within the scope of the wind-down GLs be reported even if it is "unblocked" by the wind-down GLs? See 501.603. The FAQ suggests that, where a wind-down GL authorizes...