OFAC FAQ (Current) # 976 - 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 (325 words)

* FAQ amended on 6-12-24 to update the list of Russian financial institutions that qualify for the , and again on 10-30-2024 to reflect the extended expiration date. FAQ further amended on 11-21-24 to add the final paragraph, referencing Russia-related GL 55. The text below the three dashes has not been updated since prior to 6-12-24.

---

Notes:

1) Much will turn on the scope of the term "related to energy," less so as it concerns the meaning of "energy," which is defined, and more as it concerns "related to" (how closely related?).

2) The following statement is extremely important:

For purposes of assessing whether certain transactions are authorized under GL 8, U.S. persons may rely upon the information available to them in the ordinary course of business, including reasonable reliance on information about the underlying transaction provided...

Welcome!

Welcome!

OFAC FAQ (Current) # 976 - Russian Harmful Foreign Activities Sanctions (PDF contains all versions)

TURBOFAC Commentary (325 words)