OFAC FAQ (Current) # 982 - Russian Harmful Foreign Activities Sanctions (PDF contans all versions)

Date issued: Jan. 17 2023

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TURBOFAC Commentary (656 words)

Notes:

1) Read in conjunction with FAQ # 652 and FAQ # 653. FAQ # 652 says "[a] U.S. fund that contains such blocked holdings generally is not itself considered a blocked entity, and U.S. persons may continue to invest in the fund and the fund may continue to operate." The original version of this FAQ clarified that "a U.S. fund that contains such blocked holdings generally is not itself considered a blocked entity as long as the blocked holdings represent less than a predominant share by value of debt or equity of blocked persons." This was the first articulation of the "predominant share" principle as it relates to the blocking of entire funds due to nature their holdings, rather than the owners of those holdings.

On 1-17-23, the FAQ was amended say "[i]f such blocked holdings do...