OFAC FAQ (Current) # 980 - Russian Harmful Foreign Activities Sanctions

Date issued: Feb. 24 2022

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TURBOFAC Commentary (193 words)

Notes:

1) This FAQ continues OFAC's recent trend of explicitly stating that transactions that are permissible for U.S. persons are not transactions that would (even if they theoretically could) result in the imposition of sanctions on non-U.S. persons whose activities do not otherwise have a U.S. nexus. The guidance also applies to the "material assistance" and other derivative designation criteria found in the EO. Compare FAQ # 867 (Syria secondary sanctions), FAQ # 867 (certain Iranian SDGTs), and FAQ # 545 (Russia-related secondary sanctions). Refer generally to General Note on "Counterfactual Secondary Sanctions and Derivative Designation Safe Harbors" in Certain OFAC Guidance and FAQs (System Ed. Note).

2) See Treasury Targets Russian Financial Facilitators and Sanctions Evaders Around the World (Press Release), and comments thereto, for an example of...