OFAC FAQ (Current) # 1159 - Counter Terrorism Sanctions

Date issued: Jan. 22 2024

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TURBOFAC Commentary (627 words)

Notes:

1) Paragraph (b) is a standard wind-down general license, authorizing the processing of underlying transactions even if those underlying transactions do not involve U.S. persons (see e.g., FAQ 807), but not including authorizations for the "maintenance" of activities. Refer to the Research System for documents dealing with the scope of the types of transactions that qualify for "wind down" GLs such as this. See in particular Examples of Transactions Deemed to be, and not to be, Within the Scope of the Standard "Wind-down" and "Maintenance" GLs. In FAQ # 1159, issued concurrently with this GL, OFAC clarifies that the GL includes “includes transactions necessary to wind down leases, refueling contracts, and other commercial agreements with Fly Baghdad or to repossess aircraft leased to Fly Baghdad.”

2) Paragraph (a) temporarily authorizes "the provision, exportation, or reexportation...