FACT SHEET: Russia Sanctions and Agricultural Trade

Date issued: Jul. 14 2022

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TURBOFAC Commentary (729 words)

Notes:

1) Read in conjunction with FACT SHEET: Preserving Agricultural Trade, Access to Communication, and Other Support to Those Impacted by Russia’s War Against Ukraine.

2) This "Fact Sheet" offers a bit more in the way of interpretive guidance than is common for documents of the genre, albeit nothing particularly notable.

(i) OFAC implicitly confirms that “insurance and reinsurance services related to the transportation or shipping of agricultural commodities” are covered by the GL (i.e. "ordinarily incident" or otherwise "related to" covered ag/med transactions). OFAC has addressed reinsurance in the past, but this is rare.

(ii) OFAC says that “to the extent the importation of such products of Russian Federation origin into jurisdictions outside of the United States does not involve a sanctioned person or an otherwise prohibited transaction, non-U.S. persons are not exposed to sanctions under...