OFAC FAQ (Current) # 979 - Russian Harmful Foreign Activities Sanctions

Date issued: Feb. 24 2022

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TURBOFAC Commentary (171 words)

Notes:

1) This FAQ may have implications for GLs other than those referenced in the FAQ. To the extent that OFAC uses the term "rely on" to in the sense that it is used in the context of remittance GLs [1], i.e. as a diligence-related safe harbor, it is difficult to see why OFAC would take the may "rely on" position in the context of the ag/med and "official business" GLs issued under EO 14024, but not the other ag/med GLs and "official business" provisions found in many other sanctions programs.

[1] See e.g. 560.550:

"(c) The transferring institutions identified in paragraph (a) of this section may rely on the originator of a funds transfer with regard to compliance with paragraph (a) of this section, provided that the transferring institution does not know or have reason to know that the funds transfer...