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

Date issued: Jun. 17 2021

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TURBOFAC Commentary (296 words)

Notes:

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.”

As a technical matter, the FAQ does not make much of a concession, since “know[ing] or have reason to know” that a given transaction is prohibited is the standard that, in practice, OFAC always applies when determining whether to pursue an enforcement action. see generally 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).

Put differently,...