OFAC FAQ (Current) # 910 - COVID-related General Licenses

Date issued: Jun. 14 2023

You've hit a wall. Sign in if you have an account, learn more about TURBOFAC and subscription options, or purchase access to the text of the document on this page, the native .pdf file, and the associated TURBOFAC original commentary.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (202 words)

Notes:

*FAQ amended on 6-10-22 and 6-14-23 to account for the extension of the GL(s).

In FAQ 909, OFAC says that “financial institutions may rely on the originator of the funds transfer with regard to compliance with Iran GL N, Syria GL 21, and Venezuela GL 39, provided that the financial institution does not know or have reason to know that the funds transfer is not in compliance with such GLs.” See section 3(ii) of General Note on the Terms "Knowingly," "Should Have Known" And "Reason to Know" In the Primary Sanctions, Secondary Sanctions and Derivative Designation Contexts (System Ed. Note) for general comments on the “may rely” / “may reasonably rely” statement contained herein.

OFAC uses the “may rely on the originator” construction in situations where the authorization at...