OFAC FAQ (Current) # 883 - Burma-related

Date issued: Mar. 25 2021

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TURBOFAC Commentary (330 words)

Notes:

1) This FAQ is similar to other FAQs (see e.g. FAQ # 841) addressing designations of individual entities that were made in conjunction with the issuance of a wind-down license.

2) Notably, the FAQ states that:

"While GL 4 is in effect, wind down transactions may be processed through the U.S. financial system or involve U.S. persons, as long as the transactions comply with the terms and conditions in GL 4."

What is notable about the statement is that, with the disjunctive "or," OFAC makes it relatively clear that U.S. banks may process a transaction involving the covered entity even if the transaction does not otherwise involve a U.S. person. The proviso "as long as the transactions comply with the terms and conditions in GL 4" suggests that the essential question...