Taking Additional Measures to Degrade Russia’s Wartime Economy

Date issued: Jun. 12 2024

You've hit a wall. Sign in if you have an account, or learn more about TURBOFAC and subscription options.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (174 words)

Notes:

1) On 6-12-24 the State Department designated a number of third-country entities for Russia-related transactions. A key designation is the designation of a Turkish-based company for “providing berthing and repair services to two blocked vessels” under the “materially assists” provision. The other designations of third-country companies were for “operating in” specified sectors for providing Russia with certain sensitive goods and services, or at least this is assumed on the basis of the introduction to the document, in which the State Department says that the “designations target producers, exporters, and importers of items critical to Russia’s military-industrial base” and that the “items include items on the Common High Priority List (CHPL)”. It appears likely from the wording that some of the items weren’t necessarily on the list, but they were still of a type such that the exporter would have had a reason to know of the...