Guidance for Foreign Financial Institutions on OFAC Sanctions Authorities Targeting Support to Russia’s Military-Industrial Base

Date issued: Dec. 22 2023

Last substantive commentary amendment:
Jun. 16 2024

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TURBOFAC Commentary (746 words)

[Update - on 6-12-24, OFAC published its Updated Guidance for Foreign Financial Institutions on OFAC Sanctions Authorities Targeting Support to Russia’s Military-Industrial Base. See comments thereto, and note that the commentary below has not been amended since the issuance of the updated guidance]

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Notes:

1) Refer to comments to EO 14114 for more on section 11 of amended EO 14024, and see the list of “critical items” at Determination Pursuant to Section 11(a)(ii) of E.O. 14024, as amended by E.O. of December 22, 2023 (Effective December 22, 2023).

This guidance is unique insofar as the context is managing secondary sanctions risk, but it provides a level of “compliance”-related detail that is typical of a guidance document issued for compliance with primary sanctions prohibitions that...