Directive 1 Under Executive Order 14014 (the "MOGE Financial Services Directive")

Date issued: Oct. 31 2023

Last substantive commentary amendment:
Nov. 12 2024

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TURBOFAC Commentary (1125 words)

Notes:

[Update – on 11-12-24, OFAC implemented Directive 1 into the CFR at 525.202, and defined the term “financial services” (for purposes of the Directive) at 525.305. The below has not yet been updated to reflect the addition of 525.305]

1) Directive 1 Under Executive Order 14014 (the “MOGE Financial Services Directive”) is unlike any other active sanctions prohibition in force as of the date of its October 21, 2023 date of issuance. This is for two reasons: first, there is no type of service-specific prohibition that applies on a targeted basis (contrast the Russia-related service prohibitions that apply to all “persons located in the Russian Federation”, e.g. the May 8, 2022 professional services determination pursuant to EO 14071). In addition, this is, as of October 21, 2023, the only prohibition that applies only to...