OFAC FAQ (Current) # 989 - Russian Harmful Foreign Activities Sanctions

Date issued: Feb. 24 2022

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TURBOFAC Commentary (87 words)

Notes:

1) OFAC appears to have adopted a position of interpreting the debt and equity prohibitions of the SSI Directives harmoniously with the prohibitions found in Directive 3 under EO 14024. See comments to FAQ # 956. The FAQ repeats the guidance, found in FAQ # 956, referencing "material terms of the loan." This "materiality" threshold should be presumed to apply to other "new debt" restrictions associated with older FAQs.

* See generally General Note on the Prohibitions on Dealings in “New Debt” of Certain Sanctions Targets (System Ed. Note)