OFAC FAQ (Current) # 893 - How to Search OFAC's Sanctions Lists

Date issued: May. 06 2021

TURBOFAC Commentary (118 words)

Notes:

1) The opinion referred to the in the FAQ can be found here.

Compare FAQ # 881, addressing the "transliteration error" concerning Luokung that was corrected prior to the issuance of the injunction at issue in this FAQ. Note that FAQ # 881 was removed concurrent with the posting of FAQ # 883. FAQ #883 acknowledges a preliminary injunction against the enforcement of the EO 13959 prohibitions as they apply to Luokung. That FAQ does, nevertheless, retain some interpretive value.

2) Compare FAQ # 880, addressing an injunction as applied to the enforcement of the prohibitions of EO 13959 with respect to a different "CMC" entity (Xiaomi Corporation). The opinion in the Luokung largely tracks the reasoning of the Xiaomi case.