Russian Harmful Foreign Activities Sanctions

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Fact Sheet on Recent Changes to the Russian Harmful Foreign Activities Sanctions

Frequently Asked Questions

OFAC has compiled hundreds of frequently asked questions (FAQs) about its sanctions programs and related policies. The link below sends the user to the entire list of OFAC's FAQs.

Russian Harmful Foreign Activities Sanctions Directives

  • Directive 1 - Under Executive Order Of April 15, 2021 Blocking Property With Respect To Specified Harmful Foreign Activities Of The Government Of The Russian Federation (Superseded by Directive 1A)
  • Directive 1A -  Prohibitions Related to Certain Sovereign Debt of the Russian Federation (February 22, 2022) 
  • Directive 2 - Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions (February 24, 2022)
  • Directive 3 - Prohibitions Related to New Debt and Equity of Certain Russia-related Entities (February 24, 2022)
  • Directive 4 - Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation (February 28, 2022)

Interpretive Guidance

OFAC issues interpretive guidance on specific issues related to the sanctions programs it administers. These interpretations of OFAC policy are sometimes published in response to a public request for guidance or may be released proactively by OFAC in order to address a complex topic.

Applying for a Specific OFAC License

It may be in your and the U.S. government’s interest to authorize particular economic activity related to the Russian Harmful Foreign Activities Sanctions. Certain activities related to the Russian Harmful Foreign Activities Sanctions may be allowed if they are licensed by OFAC. Visit the link below to apply for an OFAC license.

Guidance on OFAC Licensing Policy

Certain activities related to the Russian Harmful Foreign Activities Sanctions may be allowed if they are licensed by OFAC. Below OFAC has issued guidance and statements on specific licensing policies as they relate to the Russian Harmful Foreign Activities Sanctions.

  • Licenses for Legal Fees and Costs- Guidance on the Release of Limited Amounts of Blocked Funds for Payment of Legal Fees and Costs Incurred in Challenging the Blocking of U.S. Persons in Administrative or Civil Proceedings
  • Entities Owned By Blocked Persons- Guidance On Entities Owned By Persons Whose Property And Interests In Property Are Blocked

General Licenses

OFAC issues general licenses in order to authorize activities that would otherwise be prohibited with regard to Russian Harmful Foreign Activities Sanctions.  General licenses allow all US persons to engage in the activity described in the general license without needing to apply for a specific license.

LEGAL FRAMEWORK FOR THE  Russian Harmful Foreign Activities Sanctions

The Russian Harmful Foreign Activities Sanctions program may represent the implementation of multiple legal authorities. Some of these authorities are in the form of executive orders issued by the President. Other authorities are public laws (statutes) passed by The Congress. These authorities are further codified by OFAC in its regulations which are published in the Code of Federal Regulations (CFR). Modifications to these regulations are posted in the Federal Register.

Executive Orders

  • 14071 - Prohibiting New Investment In And Certain Services To The Russian Federation In Response To Continued Russian Federation Aggression (April 6, 2022)
  • 14068 - Prohibiting Certain Imports, Exports, and New Investment with Respect to Continued Russian Federation Aggression (March 11, 2022)
  • 14066 - Prohibiting Certain Imports And New Investments With Respect To Continued Russian Federation Efforts To Undermine the Sovereignty And Territorial Integrity Of Ukraine (March 8, 2022)
  • 14039 - Blocking Property with Respect to Certain Russian Energy Export Pipelines (August 20, 2021)
  • 14024  - Blocking Property With Respect To Specified Harmful Foreign Activities Of The Government Of The Russian Federation (April 15, 2021)

Determinations

    Statutes

    Code of Federal Regulations

    • 31 CFR Part 587 - Russian Harmful Foreign Activities Sanctions Regulations

    Federal Register Notices

    • 87 FR 11297-22 - Russian Harmful Foreign Activities Sanctions Regulations
    • 86 FR 35867-21  - Publication of Russian Harmful Foreign Activities Directive 1