OFAC FAQ (Current) # 590- Ukraine-/Russia-related Sanctions (PDF contans all versions)

Date issued: Apr. 25 2022

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TURBOFAC Commentary (237 words)

Notes:

1) Broadly parallel to FAQ 580 (see comments thereto), concerning Rusal, but as of 4/2019 there has not been an agreement to delist GAZ Group as there was with Rusal.

[1] See OFAC Notification to Congress of its Intention to Terminate the Sanctions Imposed on En+ Group plc, UC Rusal plc, and JSC EuroSibEnergo, see also https://home.treasury.gov/news/press-releases/sm592, announcing the de-listing.

2) See comments to FAQ 542 and FAQ 545, and note the difference in the respective scopes of SSIDES section 10 and UFSA section 5, where the former applies to SDNs and all entities blocked by operation of law, and the latter applies to only listed SDNs.

3) See pertinent interpretive Guidance Letter at Case No. Ukraine-EO13662-2018-354754-1 (2018). See also General Note on Sanctions...