OFAC FAQ (Current) # 988 - Russian Harmful Foreign Activities Sanctions

Date issued: Feb. 24 2022

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TURBOFAC Commentary (142 words)

Notes:

1) FAQ serves to clarify that the Directive is a "less-than-blocking" sanction. Concerning the following statement:

It is important to note that each directive operates independently of the others. For example, if a transaction involves a person subject to two separate directives, a U.S. person engaging in that transaction must comply with both directives.

Note that while Directive 3 under Executive Order (E.O.) 14024 contains prohibitions that are substantively identical to those found in some SSI Directives, being subject to both directives can have material consequences. Ukraine General License Number 1 authorizes otherwise prohibited derivatives trades on an across-the-board basis, but there is no similar GL that applies to Directive 3 under Executive Order (E.O.) 14024. Some entities are subject to SSI Directives as well as Directive 3 under Executive Order (E.O.)...