OFAC FAQ (Removed) # 626 -Ukraine-/Russia-related Sanctions

Date issued: Sep. 14 2018

TURBOFAC Commentary (105 words)

Notes:

* FAQ removed at some point in 2020, presumably because GLs 14 and 16 were revoked subsequent to the removal of sanctioned entities at issue from the SDN list.

1) Refer to comments to FAQ 625; note implicit relevance of FAQ to secondary sanctions scenarios, where the secondary sanctionability of a transaction not involving the U.S. depends on whether it would require a specific license if engaged in by a U.S. person (Case No. Ukraine-EO13662-2018-354754-1).

2) See generally Examples of Transactions Deemed to be, and not to be, Within the Scope of the Standard "Wind-down" and "Maintenance" GLs