OFAC FAQ (Current) # 981 - Russian Harmful Foreign Activities Sanctions (PDF contains all versions)

Date issued: Mar. 02 2022

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TURBOFAC Commentary (146 words)

Notes:

1) This FAQ is notable for (i) the due diligence-related safe harbor that is otherwise not apparent from the face of the GL (may rely upon the information available to them in the ordinary course of business), as well as (ii) the statement that "as part of a divestment transaction to a non-U.S. person, U.S. persons may engage in purchases of or investment in covered debt or equity if ordinarily incident and necessary to buy to cover a short position in such holdings." This guidance appears to have implications outside of the Russian context.

2) For comments on purchases to cover short positions, refer to section II(f) of General Note on GLs and Other Types of Authorizations as Applied to Dealings in or Related to Securities of Sanctioned Issuers.

3) Amended on...