OFAC FAQ (Current) # 903 - Chinese Military Companies Sanctions

Date issued: Jun. 03 2021

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TURBOFAC Commentary (127 words)

Notes:

1) See section II(ii) Consolidated Comment on the Chinese Military Companies Sanctions Under the EO Issued June 3, 2021 for discussion of the relationship between the EO and the "facilitation" prohibition that is implicit in all OFAC-administered regulations. As is the case with FAQ # 863, this FAQ appears to constitute a significant, one-off interpretation of the "facilitation" prohibition that is implicit in all OFAC-administered sanctions programs. FAQ # 863, where OFAC says that certain activities would be “considered permissible,” here OFAC prefaces the FAQ with “[f]or purposes of E.O. 13959” (suggesting that the logic cannot be extended to other sanctions programs). The activities described here would fall squarely within the standard “facilitation” prohibition in the context of an ordinary sanctions prohibition.