OFAC FAQ (Current) # 975 - Russian Harmful Foreign Activities Sanctions

Date issued: Feb. 24 2022

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TURBOFAC Commentary (794 words)

Consolidated comment to FAQs 975 and 990

1) FAQ # 975 and FAQ # 990 interpret, among others, two otherwise standard "wind down" GLs that do not contain any caveats or limitations on their faces. See Russian Harmful Foreign Activities General License 3 and Russia-related General License 11. In other sanctions programs OFAC has interpreted similarly worded GLs to authorize the unblocking of property with no apparent restrictions. Compare Venezuela General License 11 and Iran General License (No. K), where the wind-down GLs acknowledge that the text virtually identical to that of paragraph (a) here authorizes the unblocking of property.

This notwithstanding, OFAC has, in effect, used the guidance in FAQs 975 and 990 to impose substantial limitations on Russia-related GLs 3 and 11 that are not otherwise evident from the faces...