As Russia Completes Transition to a Full War Economy, Treasury Takes Sweeping Aim at Foundational Financial Infrastructure and Access to Third Country Support

Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.

Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.

TURBOFAC Commentary (206 words)

Notes:

1) On 6-12-24 the OFAC designated a number of third-country entities for Russia-related transactions. The designations of third-country companies were for materially assisting blocked persons or for “operating in” specified sectors of the Russian economy. On the basis of the paragraph introducing the designations, they appear to qualify as designations consistent with the pre-existing policy of targeting exporters of “Common High Priority List” or otherwise sensitive items with a military use.

SANCTIONS EVASION, CIRCUMVENTION, AND BACKFILL

Russia relies on complex transnational supply chains to feed its war machine and enable production of materiel to sustain its war effort. Similar networks also attempt to evade sanctions using convoluted schemes to move money and other valuable goods and assets. Today’s action targets more than a dozen of these types of networks, designating more than 90 individuals and entities across Russia, Belarus, the British Virgin...

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As Russia Completes Transition to a Full War Economy, Treasury Takes Sweeping Aim at Foundational Financial Infrastructure and Access to Third Country Support

TURBOFAC Commentary (206 words)