Directive 4 - Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation (May 19, 2023) (Original and amended included)

Date issued: May. 19 2023

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TURBOFAC Commentary (59 words)

Notes:

1) See related FAQs: FAQ # 998, FAQ # 999, FAQ # 1000, FAQ # 1001, FAQ # 1002, FAQ # 1003, FAQ # 1004, FAQ # 1005 and FAQ # 1118 (in re: "exit tax"). See in particular FAQ # 1005, providing guidance suggesting that the prohibition is narrower than the blocking prohibition, at least in some respects, and FAQ # 1118. See also Russia-related GL 13

2) RELATIONSHIP TO BLOCKING PROHIBITION


Note that neither "transaction" nor "transaction involving" are defined terms of art, but the totality of OFAC's guidance related to Directive 4 suggests that "transaction involving" includes the provision/receipt...