Treasury Hardens Sanctions With 130 New Russian Evasion and Military-Industrial Targets

Date issued: Nov. 02 2023

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TURBOFAC Commentary (238 words)

Notes:

1) OFAC designates a number of UAE, Turkish and other entities for "operating in" the technology and electronics sectors of the Russian economy in connection with their supply, to Russia, of sensitive goods (more specifically the high-priority items identified by the international coalition imposing sanctions and export controls on Russia). Given the context of these designations occurring in the midst of the Russia-Ukraine war, the USG appears to take the view that the exportation (particularly bulk exportation) of these goods to Russia is inherently ‘nefarious’ in a way that puts these designations outside the scope of the category of “ordinarily arm’s length international trade transactions” of a sort described in Introductory Note Common to all Derivative Designation Notices Included in the Research System. Accordingly, we do not regard all such designations to rise to the level of a “de...