OFAC FAQ (Current) # 911 - COVID-related General Licenses (All versions included)

Date issued: Jun. 14 2023

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TURBOFAC Commentary (182 words)

Notes:

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

In FAQ # 911 OFAC says “Non-U.S. persons do not risk exposure under U.S. sanctions for engaging in certain activities to respond to the COVID-19 pandemic that would be authorized under Iran GL N, Syria GL 21, or Venezuela GL 39, as appropriate, if engaged in by a U.S. person.”

This is generally consistent with OFAC’s across-the-board policy of not exercising its discretion to sanction a person for activities that would otherwise not be prohibited for a U.S. person (refer generally to General Note on "Counterfactual Secondary Sanctions and Derivative Designation Safe Harbors" in Certain OFAC Guidance and FAQs (System Ed. Note)). In the Venezuela context there are no formal “secondary sanctions,” but the derivative designation criterion...