OFAC FAQ (Current) # 1093 - Nicaragua

Date issued: Oct. 24 2022

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TURBOFAC Commentary (101 words)

Notes:

1) See Nicaragua General License 4. This GL does not provide muc in the way of interpretive guidance, except that it assures non-U.S. persons that OFAC will not use the "materially assists" derivative designation criterion in connection with transactions that would be authorized for U.S. persons. See generally General Note on Secondary Sanctions and “Derivative Designation” Criteria; Identification of the Gap Between the Theoretical and Practical Scopes of Authorities Targeting Transactions with no U.S. Nexus; Enforcement Risk Management and General Note on "Counterfactual Secondary Sanctions and Derivative Designation Safe Harbors" in Certain OFAC Guidance and FAQs (System Ed. Note).