OFAC FAQ (Current) # 542 - Section 226 (CAATSA) - Imposition of Sanctions with Respect to Foreign Financial Institutions (FFIs) (PDF contans all versions)

Date issued: Apr. 29 2022

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TURBOFAC Commentary (636 words)

Notes:

1) FAQ amended on 4-29-22 to the implementation of section 5 of UFSA into the URSR (at 589.209). The new FAQ # 542 conforms the substance of the old version of the FAQ to the provisions of the URSR that implement section 5 of UFSA, i.e. the new 589.209 and 589.413. It now clear, from new 589.209 and 589.413, that the sanctioned persons with respect to which section 5 of UFSA secondary sanctions apply are limited to those blocked pursuant to an executive order incorporated into the URSR. This means that EO 14024 is not an “Executive order addressing the crisis in Ukraine,” for the purposes of section 5 of UFSA. Up through the issuance of the new URSR, this was...