OFAC FAQ (Current) # 1105 - 12/20/22 Regulatory Amendments

Date issued: Dec. 20 2022

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TURBOFAC Commentary (193 words)

Notes:

1) FAQ # 1105, FAQ # 1106, FAQ # 1107 and FAQ # 1108 were all issued concurrently with the publication of the FR notices [1] implementing over 100 new GLs across dozens of OFAC's sanctions programs. See "Improving Humanitarian Aid Delivery by Expanding Authorizations Across U.S. Sanctions" (State Department Press Statement - https://www.state.gov/improving-humanitarian-aid-delivery-by-expanding-authorizations-across-u-s-sanctions/).

Note that while the GLs added on 12-21-22 are case as an action to "implement...UNSCR 2664" (http://unscr.com/en/resolutions/2664), there is nothing to suggest that the text of UNSCR 2664 is relevant to the actual interpretation of the otherwise standard GLs added to the regulations on 12-21-22. In other words, the GLs "implement" UNSCR 2664 in the same way that OFAC has historically used full blocking sanctions pursuant to the UNPA to "implement'' UNSC-imposed sanctions,...