OFAC FAQ (Current) # 463 - North Korea Sanctions

Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.

Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).

Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category). Please contact [email protected] or [email protected] with any questions on search results and efficiency.

Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.

TURBOFAC Commentary (210 words)

Notes:

1) This FAQ was amended/replaced on 2-15-24 to account for the implementation of a substantially amended version of the at 510.512.

2) The original version of the FAQ did not provide much in the way of interpretive guidance as it related to the original version of the GL, but note that

3) A notable distinction between the original and amended versions of the FAQ is that the amended version has a statement reading follows:

"Additionally, § 510.512(c) explicitly authorizes U.S. depository institutions, U.S.-registered brokers or dealers in securities, and U.S.-registered money transmitters to process transfers of funds on behalf of U.S. or third-country NGOs, including to or from North Korea, in support of the activities described above."

This statement...

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OFAC FAQ (Current) # 463 - North Korea Sanctions (PDF contains all versions)

TURBOFAC Commentary (210 words)