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under section 2(g) of e.o. 13692, any person that has previously transferred or sought to transfer value from a sanctioned organization or blocked person may not transfer value by any means or in any manner to, through, or from any person or entity located in the russian federation without specific authorization from ofac, or with respect to any person or entity that subsequently is designated by ofac as such a person or entity to be subject to the secondary sanction of e. 13692. after the designation, such person may not transfer value with respect to any person or entity that is subject to the secondary sanction of e. the united states government entities must seek and obtain authorization from ofac before they transfer any funds or property to or through any person or entity located in the russian federation. any person or entity located in the russian federation may transfer funds or property to or through a person or entity located in the russian federation, only with the prior approval of ofac. ofac may authorize the transfer of funds or property to or through a person or entity located in the russian federation for purposes that are directly related to the sanctionable activities of such person or entity. approval of a transfer of funds or property to or through a person or entity located in the russian federation may be conditioned upon the imposition of an alternative sanction pursuant to e. 13692, or the person or entity receiving the funds or property may consent to the imposition of an alternative sanction pursuant to e.
the sdn list is updated on a daily basis to list individuals and entities in the russian federation that have been designated by ofac as blocking persons, based upon ofac’s determination that these individuals or entities are providing or have provided goods, services, or technology that benefit or are intended to benefit the russian federation. ofac also determines whether an entity located in the russian federation that is owned or controlled by the designated blocking persons meets the criteria for inclusion on the sdn list. for purposes of ofac’s sdn determination, the term “russian federation” includes the territory of the former soviet union, which is defined by the department of state as the state of russia, ukraine, belarus, kazakhstan, kyrgyzstan, tajikistan, turkmenistan, and uzbekistan. the fact that an entity located in the russian federation is subject to the sanctions imposed by e.o. 13,692 does not constitute a determination by ofac that the entity meets the criteria for inclusion on the sdn list.
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