OFAC FAQ (Current) # 1097 - Counter Terrorism Sanctions (PDF contains all versions) (PDF contains all versions)

Date issued: Jan. 12 2023

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TURBOFAC Commentary (102 words)

Notes:

1) See comments to GTSR General License 21. This FAQ provides no meaningful guidance on the scope of the GL, and appears aimed at clarifying that, consistent with OFAC’s typical policy, non-U.S. persons do not risk sanctions enforcement for activities that would be authorized for U.S. persons under the GL. Refer generally to General Note on "Counterfactual Secondary Sanctions and Derivative Designation Safe Harbors" in Certain OFAC Guidance and FAQs (System Ed. Note).

2) FAQ amended on 1-12-23 to account for issuance of GTSR General License 21B and extension of expiration date vis-a-vis the previous version.