OFAC FAQ (Current) # 411 - Ukraine-/Russia-related Sanctions

Date issued: Nov. 28 2017

TURBOFAC Commentary (56 words)

Notes:

1) Refer to comment to FAQ 372 re: the significance of including derivatives within the scope of the directives. OFAC takes the same position in all three programs (Belarus, Russia, Venezuela) that contain "new debt" prohibitions.

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