On 7 May 2015, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued three updates to its Frequently Asked Questions related to Russia and Ukraine. OFAC revised the answer to FAQ No. 395, which deals with letters of credit, to clarify that US persons may deal in letters of credit issued by Russian banks on the Sectoral Sanctions Identifications (“SSI”) list if the underlying payment terms comply with the 30-day debt limit imposed by the SSI. OFAC also amended the answer to FAQ No. 419, which deals with commercial transactions, to specify that payments received from SSI-listed entities should use a value date of not later than 30 days (or 90 days under Sectoral Sanctions Directive 2) from the point at which title or ownership has transferred for payments relating to sales of goods, or from the date of each final invoice for payments relating to services, subscription arrangements, and progress payments. OFAC maintained its existing guidance that the payments must be received within the 30-day (or 90-day) period after the transfer of title or ownership, or the issuance of each final invoice, as applicable. Finally, OFAC issued a new FAQ No. 453 clarifying that US financial institutions are allowed to service noncommercial personal remittances to Crimea even if neither the beneficiary nor the remitter is a US person