31 CFR § 546.512 - Authorizing Certain Transactions in Support of Nongovernmental Organizations’ Activities.

Date issued: Mar. 05 2024

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TURBOFAC Commentary (763 words)

Notes

1) On 12-21-22, OFAC issued over 20 GLs similar to this one to list-based sanctions programs that did not previously have GL for “Certain Transactions in Support of Nongovernmental Organizations’ Activities”. The GLs are substantively identical across programs.

2) Refer generally to General Note on GLs Authorizing Transactions of and Related to Nongovernmental Organizations (NGOs) (System Ed. Note), for comments on the scope and operation of standard “NGO” GLs, but note that there are two aspects of the GLs implemented on 12-21-22 that differs from previously issued NGO GLs.

(i) Subsection (b) of this and all similar GLs carves out “funds transfers initiated or processed with knowledge or reason to know that the intended beneficiary of such transfers is a person blocked pursuant to this part, other than for the purpose of...