OFAC FAQ (Current) # 978 - Russian Harmful Foreign Activities Sanctions (PDF contains all versions)

Date issued: Jun. 14 2022

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TURBOFAC Commentary (186 words)

Notes:

1) Compare Archived Cuba FAQs - # 6, and the related graphic. This is effectively a "U-turn" GL.

2) The FAQ clarifies what is not clear from the GLs referenced, i.e. that the involvement of blocked banks is authorized when the blocked banks are involved in the processing of underlying transactions described by the GLs.

3) Query: can the blocked banks referenced be involved in transactions where the underlying transaction is exempt, e.g., an exempt informational materials or travel transaction? It would appear so.

4) Query: why do GLs 6, 7 and 8 contain a "correspondent account or payable-through account" exclusion, while GL 5 (Official Business of Certain International Organizations and Entities) does not? Can the United Nations Federal Credit Union maintain a correspondent account for...