OFAC FAQ (Current) # 1145 - Global Magnitsky Sanctions

Date issued: Dec. 08 2023

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TURBOFAC Commentary (600 words)

Notes:

1) On February 25, 2022, OFAC issued GTSR/FTOSR General License 20, which generally licensed certain dealings involving persons blocked pursuant to the GTSR were the transactions involved "Afghanistan or [generally non-blocked] governing institutions in Afghanistan". This generally mooted the otherwise key question of when a blocked Taliban member that leads or controls a governing institution in Afghanistan has an interest in a transaction involving such institution.

On December 9, 2023, OFAC blocked, among other individuals, the heads of the " Afghanistan Academy of Sciences" and "Ministry for the Propagation of Virtue and Prevention of Vice" pursuant to EO 13818, against which GTSR/FTOSR General License 20 does not license. (See https://home.treasury.gov/news/press-releases/jy1972).

For transactions involving those two entities, it is once again necessary to determine...