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

Date issued: Jun. 17 2021

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TURBOFAC Commentary (149 words)

Notes:

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. In the Venezuela context there are no formal “secondary sanctions,” but the derivative designation criterion for providing “material assistance” to a person blocked pursuant to EO 13850 has, as a practical matter, been deployed in a manner that produces the same effect as a “secondary sanction” provision applicable to significant trade transactions....